Client Assets CASS

Client assets protection

In an environment of increasing internal and external stakeholder pressure on financial institutions to put client assets protection at the heart of their business objectives, Deloitte can quickly and successfully deploy professional services solutions and teams dedicated to supporting companies in achieving this important goal.

We work with a wide range of financial institutions from incumbents in the capital, retail and wealth management sectors, to the FinTech disruptors such as crowdfunding and peer-to-peer platforms. Using our broad range of professional services solutions, underpinned with deep industry experience and regulatory knowledge, we offer design and implement solutions as well as monitoring and remediation services.

We offer a range of services to help financial institutions meet their regulatory obligations and protection of client assets. We combine deep regulatory technical insight with experience from industry experts, as well as practical approaches to implement solutions which are anchored on our Consumer and Assets Protection Framework.

Our services are deployed to help companies proactively manage and achieve client assets protection as a result of a range of drivers such as:

  • FCA Regulatory Visits and Review
  • External FRC Standard CASS Audit
  • Business Acquisition, Disposal and Consolidation
  • Regulatory Change
  • New Business
  • System Change and Migration
  • Out-sourcing and In-sourcing
  • CASS Risk Management

Our approach focuses on the core principle of the client assets protection regime, which is to ensure that client assets are appropriately segregated in the event of a firm’s insolvency and that they are returned to customers without undue delay. We help our clients achieve good practices and avoid the following poor practices that threaten this fundamental principle which may lead to customer detriment and / or loss of client assets:

  • Inherent poor design of the business model: The potential for an asset shortfall, leading to insufficient client money or custody assets segregated will increase greatly if the inherent design of the business model is not appropriately considered from a client assets protection perspective. We work with companies to design and assess their business and target-operating model to ensure these risks are identified early, throughout the product design and trade lifecycle. We then support companies in either amending the business model or designing and implementing suitable controls to address the risks. 
  • Bad culture and tone from the top: Good governance and senior stakeholder involvement in setting the right cultural tone from the top is critical to ensure clients assets protection is taken seriously and are at the heart of a company’s business objectives. We help firms put in place CASS governance arrangements and provide bespoke training to CXOs and senior management teams to ensure they are sufficiently skilled and knowledgeable to grasp the CASS regulatory requirements.
  • Slack control, checks and balances: Companies are expected to have adequate internal controls to ensure client assets protection is achieved and regulatory requirements are met. We assist companies in the design and implementation of their client assets protection risk and control framework, and provide assessments of the adequacy of the control activities throughout all functional areas across the front office, middle office, back office operations, and legal.
  • Poor monitoring and audit reviews: Companies may well believe they have adequately designed control activities to ensure regulatory requirements are met and client assets are protected, but the role of second line compliance and third line internal audit is critical to show the control activities are operating as expected. We work with both compliance and internal audit functions to ensure their monitoring and audit plans are well thought-through and have adequate coverage of key CASS risks and issues.

Key contacts

Michael W Williams

Michael W Williams


Mike leads the Banking Regulation team in the London Banking & Capital Markets Group. Having founded the Deloitte regulatory practice in 1992, Mike has a wide ranging knowledge of UK Prudential Regula... More

Dennis Cheng

Dennis Cheng


Dennis is a Director in our Banking and Capital Markets Audit and Assurance Practice in London. His areas of specialism are the trading activities and back office operations of financial institutions ... More