Practical guidance series, Theme 1, Part 2 of 6 Part 1 covered getting the daily client money calculation right. That calculation only means something if it’s checked against reality, which is what reconciliation does, and it’s where the next layer of CASS audit findings tends to show up. What it looks like in practice The…
Practical guidance series, Theme 1, Part 1 of 6 This opens a six-part walk-through of where firms most often generate findings in a CASS audit, working through the control environment in a logical build. It starts here, with the client money calculation (CMC) itself, because every other control in the series depends on this figure…
Practical guidance series, Theme 1, Part 3 of 6 Part 2 covered reconciliation discipline. This part steps back one level further, to the legal foundation underneath it: whether the account being reconciled is actually the right kind of account, and whether it genuinely has the trust status CASS requires. What it looks like in practice…
Practical guidance series, Theme 1, Part 4 of 6 Part 3 covered the legal foundation of the client bank account itself: trust status and the acknowledgment letter. Once that foundation is sound, the next place CASS audits generate findings is the everyday mechanics of moving money into and out of that account. Getting the calculation…
Published 2 October 2026 On 16 September 2026, two weeks before its cryptoasset authorisation gateway opened, the FCA published PS26/18, its policy statement on Perimeter Guidance (PERG) for the new UK cryptoasset regime. The timing was not an accident. Firms needed to know, before they could even start an application, whether what they do actually…
Ask three people at a payment or e-money firm what “client money” means and you will often get three different answers, and at least one of them will be wrong. That matters more than it used to. Since the FCA’s new CASS 15 chapter came into force on 7 May 2026, firms authorised under the…
If you run, or advise, a UK-authorised payment institution, e-money institution, or crypto firm, you have almost certainly heard the word “CASS” thrown around by auditors, banking partners, or the FCA itself. For firms that grew up outside the traditional investment world, it can be confusing: CASS wasn’t originally written with you in mind, yet…
News & regulatory update — clientmoney.co.uk Two developments from this summer are worth a compliance officer’s attention this week: a substantial FCA enforcement outcome that turns on a firm’s failure to check a counterparty’s actual permissions before holding client assets, and the practical mechanics of the first safeguarding audit cycle now running under CASS 15….
On 30 June 2026 the FCA published the core rulebook for the UK’s new cryptoasset regime — five policy statements (PS26/9 through PS26/13) covering everything from stablecoin issuance to market abuse. Buried in that package, but arguably the single most consequential piece for firms already living inside CASS, is the creation of CASS 17: a…
Last reviewed: July 2026 Quick answer: CASS 15 requires payment and e-money firms to run two distinct reconciliations — internal and external — on every reconciliation day, comparing what the firm should be safeguarding against what it actually holds. Any shortfall must be corrected from the firm’s own funds by the end of the day…
