CASS And The Importance Of Protecting Your Clients’ Money

The collapse of Lehman Brothers in 2008 was the catalyst for a global financial crisis that has permanently altered the way in which compliance is carried out and understood. One key alteration was a new emphasis on firms’ protecting their clients’ monies and assets.

In today’s financial landscape, protecting clients’ monies and assets is a fundamental requirement of an effective compliance program. If a firm fails – whether it be a bank, e-money issuer, payment provider, insurer, or asset manager – then the customers of that firm need to know that their monies are safe and can easily be repaid without any issues.

There is an expectation that clients’ assets will be returned without delay or the need for insolvency practitioners or legal intervention. Financial services providers in the UK that hold or control clients’ monies or assets are required to follow the rules outlined by the Financial Conduct Authority’s (FCA) Client Asset Sourcebook (CASS).[1]

What Is CASS?

The CASS rules were created to ensure that client assets are safeguarded in the event of a worst-case scenario of a firm becoming insolvent. The rules were established in line with the FCA’s Principle 10, which states that a firm ‘must arrange adequate protection for clients’ assets when it is responsible for them.’

The CASS rules, which can be found in the FCA Handbook and which consist of 14 chapters, include general provisions, as well as how to apply them depending on the nature and size of the business.

They detail how to segregate client money from company money and the correct recordkeeping requirements, among many other requisites. The rules also classify firms depending on the amount of client money in their possession.

Under the CASS rules, firms are separated into three different classification types.

  • CASS Large Firm: if the highest total amount of client money a firm held in the last calendar year is more than £1 billion, they are most large.
  • CASS Medium Firm: if the highest total amount of client money a firm held in the last calendar year is an amount equal to or greater than £1 million and less than or equal to £1 billion, the firm is medium.
  • CASS Small Firm: if the highest total amount of client money the firm held in the last calendar year is less than £1 million, the firm is small.

Why Protect Clients’ Money?

There are many benefits associated with safely and correctly protecting clients’ money. First, clients will trust the firm if they know that their assets are safe, are being segregated appropriately from company funds, and know they will be returned if anything were to happen to the company. This can lead to an improvement in company reputation and, as a result, more customers looking to come on board.

Second, by protecting clients’ money correctly and in accordance with the designated rules, firms keep regulators happy and off their backs. This negates any risk of a firm receiving regulatory actions such as warnings or fines.

Finally, stakeholders within the firm can operate with confidence, knowing that the rules are being adhered to. This is beneficial for the whole firm, with employees more satisfied working for a company doing the right thing, senior leadership instilling confidence across the business, and investors knowing that they are investing in a firm that has their clients’ assets adequately protected.

Failing To Protect Clients’ Money

If client money is not protected, either through the comingling of clients’ assets with company assets, not returning clients’ money, or losing it in legal complexities, firms can suffer serious consequences.

Regulators can and will impose extremely high fines for failing to comply with the rules, and these fines can be eye-watering. JP Morgan, for instance, was fined £33 million for its failure to segregate client money totaling between $1.96—$23 billion.[2] Fines of such magnitude can obviously have a serious impact on a firm’s liquidity.

A failure to comply can also lead to a lack of trust in the firm. This can have a profound impact on a firm’s reputation, which in turn can result in:

  • customers going elsewhere
  • a loss of revenue
  • disgruntled shareholders
  • negative media, and
  • employees moving to competitors.

A bad reputation can be critical, and its impact can be difficult to reverse or halt. If a firm cannot improve its poor reputation, it can, in extremis, lead to them eventually going out of existence.

Finally – as the Lehman Brothers bankruptcy revealed – whole markets can be impacted by the actions of a single firm. A repeat of the global financial crisis of 2008 would be disastrous.

It is, however, avoidable if firms follow the rules put in place by regulators. Any failure to comply could see history repeat itself in ways unwelcome to the firm in question, its employees, and wider society.  

Written by Jon Prentice

This article was first published by the International Compliance Association (ICA), the leading professional body for the global regulatory and financial crime compliance community. For more information on the benefits of becoming an ICA member, including access to the ICA’s complete content library of articles, videos, podcasts, blogs, and e-books, visit: Become an ICA Member – Application Form (


[1] FCA, ‘FCA Handbook: CASS 1.1 Application and purpose’: 

[2] FCA, Final Notice: J.P. Morgan, 25 May 2010: 


Lavanya Rathnam

Lavanya Rathnam is an experienced technology, finance, and compliance writer. She combines her keen understanding of regulatory frameworks and industry best practices with exemplary writing skills to communicate complex concepts of Governance, Risk, and Compliance (GRC) in clear and accessible language. Lavanya specializes in creating informative and engaging content that educates and empowers readers to make informed decisions. She also works with different companies in the Web 3.0, blockchain, fintech, and EV industries to assess their products’ compliance with evolving regulations and standards.

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