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Client Money Audit
Financial Crime & Audit
Client Money Audit Services
Independent Client Money Audit Services That Strengthen FCA Compliance
Client Money Audit Services help FCA-regulated firms ensure they protect client funds in line with the Financial Conduct Authority (FCA) and Client Assets Sourcebook (CASS) requirements. Independent audits assess governance, client money segregation, reconciliations, and internal controls to identify compliance gaps before they become regulatory issues.
At Acumen Global Compliance Ltd, we provide independent Client Money Audit Services across the UK. Backed by over 15 years of regulatory expertise, we support payment institutions, Electronic Money Institutions (EMIs), fintech companies, investment firms, insurance brokers, and other regulated businesses with practical, risk-based audits that strengthen compliance, reduce regulatory risk, and prepare firms for FCA supervisory reviews.
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What is a Client Money Audit?
A Client Money Audit is an independent review that assesses whether a firm manages client funds in compliance with FCA rules and the Client Assets Sourcebook (CASS). It evaluates the effectiveness of your safeguarding arrangements, internal controls, governance, and record-keeping to identify compliance gaps and reduce regulatory risk.
A comprehensive Client Money Audit typically reviews:
- Client money segregation arrangements
- Client account structures
- Daily and periodic reconciliations
- Internal controls
- Governance and oversight
- Risk management processes
- Policies and procedures
- Record keeping
- Third-party banking arrangements
- Senior management responsibilities
- Compliance monitoring programmes
A well-executed Client Money Audit helps strengthen compliance, improve operational resilience, and demonstrate effective governance to the FCA.
Who Needs a Client Money Audit?
Any organisation that holds, safeguards, or controls client funds should regularly review its compliance framework. Depending on the firm’s permissions and regulatory obligations, an independent client money audit may be required by law or considered a regulatory best practice.
Acumen Global Compliance supports a wide range of regulated businesses across London and the wider UK.
Payment Institutions
Authorised and Small Payment Institutions that safeguard customer funds should regularly assess whether their safeguarding arrangements, reconciliations, and governance meet FCA expectations.
Electronic Money Institutions (EMIs)
Electronic Money Institutions must maintain effective safeguarding measures for customer funds. Independent audits help demonstrate that these controls operate effectively and support ongoing regulatory compliance.
Investment Firms
Investment firms subject to the FCA's Client Assets Sourcebook (CASS) often require independent CASS audits to verify compliance with client asset and client money rules.
Insurance Brokers
Insurance intermediaries holding client premiums may fall within the scope of CASS 5 requirements and benefit from periodic client money compliance reviews.
FinTech Companies
Rapidly growing fintech businesses often experience operational changes that increase compliance risk. Independent client money audits help ensure governance frameworks keep pace with business growth.
Wealth Management Firms
Firms managing client investments or assets should regularly review client asset controls to maintain investor confidence and regulatory compliance.
Money Service Businesses
Remittance providers and other Money Service Businesses handling customer funds should regularly review safeguarding controls to strengthen compliance and reduce financial crime risk.
FCA Client Money Rules and CASS Explained
The Financial Conduct Authority (FCA) regulates how firms protect client money through the Client Assets Sourcebook (CASS). These rules help safeguard client funds, ensure regulatory compliance, and maintain confidence in the UK financial services sector.
Key FCA Client Money Rules
What is CASS?
The Client Assets Sourcebook (CASS) sets out the FCA rules for protecting, segregating, reconciling, and managing client money and client assets.
CASS 5
Applies to insurance intermediaries and covers client money segregation, trust arrangements, reconciliations, and record-keeping.
CASS 6
Focuses on protecting custody assets held by investment firms.
CASS 7
Sets out the main client money rules for investment firms, including segregation, reconciliations, governance, and operational controls.
Client Money Segregation
Client funds must be kept separate from the firm's own money in designated client accounts.
Client Money Reconciliations
Regular reconciliations ensure client money records are accurate and any discrepancies are identified promptly.
Record Keeping
Firms must maintain accurate, complete, and accessible records to demonstrate ongoing FCA compliance.
Our Independent Client Money Audit Services
At Acumen Global Compliance Ltd, we provide independent Client Money Audit Services to help FCA-regulated firms comply with the FCA and Client Assets Sourcebook (CASS) requirements. With over 15 years of regulatory expertise, we deliver practical, risk-based audits that strengthen governance, improve internal controls, and reduce compliance risk.
Our Client Money Audit Services Include
Independent Client Money Audits
Assess compliance with FCA client money rules.
CASS Compliance Audits
Review compliance with CASS 5, CASS 6, and CASS 7 requirements.
Client Money Compliance Reviews
Evaluate governance, reconciliations, and safeguarding controls.
Safeguarding Reviews
Assess safeguarding arrangements for Payment Institutions and EMIs.
Internal Control Assessments
Review policies, procedures, and operational controls.
Regulatory Readiness Assessments
Prepare your business for FCA supervisory visits and regulatory audits.
Benefits of an Independent Client Money Audit
An independent client money audit provides far more than regulatory assurance. It enables businesses to improve operational resilience, strengthen governance, and build greater confidence with regulators, customers, and business partners.
Strengthen FCA Compliance
Demonstrate your commitment to meeting FCA expectations through an independent review of your client money arrangements.
Reduce Regulatory Risk
Identify compliance weaknesses before they result in supervisory findings, enforcement action, or customer harm.
Improve Governance
Enhance board oversight, accountability, and internal control frameworks by addressing gaps identified during the audit.
Protect Customer Funds
Strong client money controls reduce the likelihood of errors, safeguarding failures, and operational losses, helping to protect customers and maintain trust.
Client Money Segregation
A well-governed compliance framework gives investors, banking partners, and regulators greater confidence as your business expands.
Enhance Operational Efficiency
Audit findings often identify opportunities to streamline reconciliation processes, improve record keeping, and strengthen internal workflows.
Prepare for FCA Supervision
Businesses with mature governance frameworks and documented controls are generally better prepared for FCA supervisory reviews and regulatory inspections.
Industries We Support
We provide Client Money Audit Services to a wide range of FCA-regulated firms across the UK, with audits tailored to each industry’s regulatory requirements.
Payment Institutions
Assess safeguarding arrangements and FCA compliance.
Electronic Money Institutions (EMIs)
Review governance, reconciliations, and safeguarding controls.
Investment Firms
Conduct independent CASS and client money audits.
Insurance Brokers
Evaluate CASS 5 compliance and client money controls.
FinTech Companies
Strengthen compliance frameworks and operational governance.
Money Service Businesses (MSBs)
Review AML controls, safeguarding, and risk management.
Wealth Management Firms
Assess client asset protection and governance controls.
Cryptoasset Businesses
Support safeguarding, governance, and regulatory compliance where applicable.
Common Client Money Compliance Issues
Even well-managed firms can experience weaknesses in their client money framework. Identifying these issues early can significantly reduce regulatory risk.
Some of the most common findings include:
Inadequate client money segregation
Delayed or inaccurate reconciliations
Incomplete client money records
Weak governance and oversight
Outdated policies and procedures
Poor management information and reporting
Insufficient staff training
Lack of documented controls
Inconsistent safeguarding processes
Weak risk assessment methodologies
Failure to review third-party banking arrangements
Limited compliance monitoring
Addressing these issues proactively helps firms strengthen their compliance framework and reduce the likelihood of regulatory intervention.
Our Client Money Audit Process
We follow a structured, risk-based approach to help FCA-regulated firms assess compliance with client money and CASS requirements.
Step 1: Initial Consultation
- Understand your business model and regulatory requirements.
- Define the audit scope and objectives.
Step 2: Documentation Review
Review key documents, including:
- Client Money Policy
- Safeguarding Policy
- Risk Assessments
- Governance Framework
- Reconciliation Reports
- Compliance Procedures
Step 3: Operational Testing
Assess the effectiveness of:
- Client money segregation
- Reconciliations
- Client account management
- Internal controls
- Record keeping
- Management oversight
Step 4: Risk Assessment
Identify compliance gaps and risks related to:
- FCA regulations
- Financial crime
- Governance
- Operational controls
- Regulatory breaches
Step 5: Audit Report
Deliver a comprehensive report with:
- Key findings
- Compliance gaps
- Risk analysis
- Practical recommendations
- Remediation actions
Step 6: Ongoing Compliance Support
Assist with implementing recommendations, strengthening governance, and preparing for future FCA reviews.
Documents Required for a Client Money Audit
Preparing the right documentation helps ensure a smooth and efficient Client Money Audit.
Typical Documents Include:
Governance Documents
Governance framework, organisation structure, board minutes, risk register, and senior management responsibilities.
Compliance Documents
Client Money Policy, Safeguarding Policy, Compliance Monitoring Programme, Internal Audit Reports, and Risk Assessments.
Financial Records
Client account statements, general ledger, trial balance, and client money reconciliation reports.
Operational Documents
Bank acknowledgement letters, client agreements, outsourcing agreements, incident logs, breach registers, and operational procedures.
Internal Control Evidence
Approval processes, segregation of duties, staff training records, monitoring reports, and compliance reviews.
Maintaining accurate and up-to-date records supports FCA compliance and helps ensure a successful audit.
Why Choose Acumen Global Compliance Ltd?
At Acumen Global Compliance Ltd, we provide independent Client Money Audit Services backed by deep regulatory expertise and practical compliance solutions.
15+ Years of Experience
Supporting FCA-regulated firms across the UK.
FCA & CASS Specialists
Expertise in FCA rules, CASS, safeguarding, AML, and governance.
Independent, Risk-Based Audits
Objective assessments tailored to your business.
Practical Recommendations
Actionable solutions to strengthen compliance and reduce risk.
Trusted Compliance Partner
Supporting fintechs, payment institutions, EMIs, investment firms, and other regulated businesses.
Strengthen Your Client Money Controls Today
Managing client money requires more than meeting minimum regulatory requirements it demands robust governance, effective safeguarding, and ongoing compliance monitoring. Whether you need an independent Client Money Audit, a CASS compliance review, or support preparing for an FCA inspection, Acumen Global Compliance Ltd is here to help.
Speak with our compliance experts today to arrange a confidential consultation and ensure your client money framework meets FCA expectations while supporting your long-term business success.
FAQs
Frequently Asked Questions
Is a Client Money Audit mandatory in the UK?
Certain FCA-regulated firms are required to obtain independent assurance over their client money arrangements, while others conduct voluntary audits as part of good governance and risk management.
What is the difference between safeguarding and CASS?
Safeguarding applies to Payment Institutions and Electronic Money Institutions (EMIs), while CASS applies mainly to investment firms and insurance intermediaries. Both are designed to protect client funds but follow different FCA regulatory requirements.
How often should a Client Money Audit be carried out?
The frequency depends on the firm’s regulatory obligations, business model, and applicable FCA requirements. Many firms undertake annual audits alongside ongoing compliance monitoring.
How long does a Client Money Audit take?
Most audits take between two and six weeks, depending on the firm’s size, operational complexity, and the availability of documentation.
Can any accountant perform a CASS audit?
No. CASS audits require specialist knowledge of FCA regulations, client money rules, safeguarding requirements, and financial services governance. Firms should engage professionals with relevant regulatory expertise.
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