Mastering CASS in Practice: Governance, Compliance & FCA Expectations

Introduction

CASS remains one of the FCA’s most actively supervised areas, and the consequences of getting it wrong - whether through inadequate governance, poor breach management, or gaps in your three lines of defence can be significant. This full-day in-person seminar is designed for those who want to move beyond the basics and develop a deeper, more practical understanding of how CASS works in practice.

This seminar not only covers the vital areas of CASS compliance and governance but also incorporates a dedicated section on the most significant CASS-related regulatory developments. Rather than a traditional lecture format, the day is structured to allow time for questions, case studies, and delegate interaction throughout.

You will leave with a clearer understanding of the regulatory architecture underpinning CASS, along with the practical tools to assess and manage breaches, strengthen governance and oversight, and identify gaps in your firm’s control framework. The session will cover recent FCA supervisory and enforcement activity, including hot topics such as total capture, third party oversight, and the FCA’s evolving expectations around CASS culture.

What You Will Learn

This course will cover the following:

• CASS Architecture and Hot Topics
• The spectrum of regulations collectively referred to as CASS and the role of different regulators
• How UK regulation is made and the FCA rule-making process
• Hot topics: cryptoassets and stablecoins, Payment Services and CASS 15
• Total Capture: Client Money, Custody Assets and Mandates
• Defining client money, safe custody assets and mandates under CASS 7, 6 and 8
• Title Transfer Collateral Arrangements: risks, FCA concerns and Dear CEO letter history
• Exemptions including the banking exemption, DVP and temporary handling
• Issue Management: Notifications, Breaches and FCA Engagement
• FCA notification requirements and the distinction from Principle 11 obligations
• Why breaches can be positive, and how to assess materiality using a practical matrix
• FCA reviews, visits, skilled person reviews and the enforcement toolkit
• Governance: SMCR, Delegation and Committee Effectiveness
• CASS governance expectations and the alignment of CASS with SM&CR
• The SMF and CP: split of responsibilities and what can and cannot be delegated
• Committee effectiveness and Terms of Reference: what the FCA expects to see
• Cornerstones of the CASS Regime: The Insolvency Mindset
• Identification, segregation, reconciliation and record-keeping under CASS 6 and 7
• Resolution Packs, client money distribution rules and insolvency risk
• CASS Culture and Management Information
• What good CASS culture looks like and why it is growing in regulatory importance
• Best practice for CASS MI packs and information flow within your firm
• Oversight: Three Lines of Defence and Third Parties
• Roles and responsibilities across 1LoD, 2LoD and 3LoD in a CASS context
• Selecting, appointing and overseeing third party banks, custodians and administrators
• Common outsourcing and oversight failings identified by the FCA
• Recent CASS Updates
• Significant FCA supervisory statements, consultation papers and policy statements since 2024
• Enforcement trends: analysis of recent Final Notices and Dear CEO letters
• The FCA's approach to cryptoassets, stablecoins and the extension of CASS into new areas
• Case Studies and Open Q&A
• Scenario-based breach assessment exercise using the materiality matrix
• Open questions and delegate discussion