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Client Money Audit
Financial Crime & Audit
Client Money Audit Services
Independent Client Money Audit Services That Strengthen FCA Compliance
Protecting client money requires clear procedures, accurate records, effective oversight and controls that reflect the firm’s regulatory obligations.
Acumen Global Compliance provides client money compliance support to help regulated businesses assess their arrangements, identify control weaknesses and understand their obligations under the applicable FCA rules. Depending on the firm’s circumstances and the agreed scope, support may include a formal client money or CASS audit, a compliance review, or an audit readiness assessment.
We work with firms to examine relevant areas such as client money records, reconciliations, account arrangements, governance and internal controls. Our recommendations focus on practical steps that can help improve control effectiveness and address identified gaps.
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What is a Client Money Audit?
A client money audit examines whether a firm’s relevant client money arrangements, records and systems comply with the regulatory requirements that apply to its business.
The precise scope depends on the firm’s regulatory permissions, activities and applicable rules. For firms within the relevant CASS requirements, an audit may assess the handling of client money, the adequacy of systems and controls, and compliance with applicable client money rules.
A review may cover:
- Client money arrangements: How client funds are identified, received, held and managed.
- Account arrangements: Relevant client bank accounts, account documentation and third-party arrangements.
- Reconciliations: The accuracy, frequency and review of applicable internal and external reconciliations.
- Records and reporting: Whether records support accurate calculations, reporting and an appropriate audit trail
- Governance and oversight: Responsibilities, approvals, management information and escalation procedures.
- Policies and controls: Whether documented procedures reflect the firm's activities and applicable requirements.
- Issue management: How discrepancies, control failures and potential breaches are recorded, escalated and resolved.
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.
Investment Firms
Investment firms that hold or control client money or custody assets may be subject to relevant CASS requirements. Support can focus on the applicable rules, records, reconciliations, account arrangements and control framework.
Insurance Intermediaries
Insurance intermediaries that hold client premiums may fall within relevant CASS 5 requirements. Depending on their arrangements, some firms must obtain an external client assets report. The applicable obligation should be confirmed before work begins.
Electronic Money Institutions
Electronic money institutions must consider the safeguarding requirements applicable to their business and permissions. A safeguarding review can examine relevant funds, reconciliations, records, governance and third-party arrangements within the agreed scope.
Fintech and Financial Services Businesses
Fintech businesses should identify the regulatory requirements associated with their actual activities. Where applicable, a review may assess client money controls, safeguarding arrangements, operational governance or other relevant compliance processes.
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.
Other Businesses Handling Client Funds
Businesses in other sectors should not assume that FCA client money rules apply simply because they receive or handle money on behalf of customers. The correct regulatory framework should be established before deciding whether a CASS audit, safeguarding review or another type of assessment is appropriate.
FCA Client Money Rules and CASS Explained
The Financial Conduct Authority’s Client Assets Sourcebook (CASS) contains rules covering client money and custody assets for firms and activities within its scope. The applicable requirements vary by firm type and regulatory activity.
Key FCA Client Money Rules
CASS 5: Insurance Intermediaries
CASS 5 contains client money rules relevant to insurance intermediaries within its scope. Depending on the firm's arrangements, the assessment may cover client money accounts, trust arrangements, calculations, reconciliations and records.
CASS 6: Custody Assets
CASS 6 addresses the protection and administration of custody assets within its scope. Relevant controls may include asset records, account arrangements, reconciliations and oversight of third parties holding assets.
CASS 7: Investment Firm Client Money
CASS 7 contains client money rules for relevant investment business. Applicable requirements may cover segregation, the treatment of client money, records, accounts and reconciliations.
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, We offer support that can be scoped to the firm’s regulatory position, needs and the type of engagement required.
Our Client Money Audit Services Include
Formal Client Money or CASS Audit
Where applicable and within our confirmed audit remit, a formal audit examines relevant client money arrangements and controls against the requirements governing the firm. The scope, reporting requirements and auditor eligibility must be established before the engagement is accepted.
Client Money Compliance Review
A compliance review examines relevant policies, procedures, records, reconciliations and control arrangements to identify potential weaknesses. It can help firms prioritise corrective action but should not be represented as a statutory or independent audit unless it meets the applicable requirements.
CASS Compliance Review
A CASS review focuses on the chapters and obligations relevant to the firm's activities. The assessment may cover client money or custody asset records, account arrangements, reconciliations, governance and supporting evidence.
Safeguarding Compliance Review
For payment and e-money firms, a safeguarding review assesses relevant safeguarding arrangements under the rules applicable to the firm. Depending on the agreed scope, this may include reconciliation processes, relevant funds, records, third-party arrangements, governance and reporting.
Internal Control Assessment
An internal control assessment considers whether the firm's documented procedures and operational practices support effective oversight, accurate records and timely identification of issues.
Audit Readiness Assessment
An audit readiness assessment helps a firm organise relevant documentation, understand potential gaps and prepare evidence for an upcoming formal audit or regulatory review. It does not replace a required external audit.
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.
Identify Control Weaknesses
A structured review can help identify weaknesses in records, reconciliations, account arrangements, policies or oversight before they remain unresolved.
Improve Record Accuracy
Reviewing relevant records and reconciliation procedures can help firms identify inconsistencies and improve the quality of the evidence supporting their client money arrangements.
Strengthen Governance and Accountability
Clear responsibilities, documented approvals and effective escalation procedures help senior management understand how relevant controls are operating.
Improve Issue Resolution
A documented process for recording, investigating and escalating discrepancies can help the firm manage potential control failures more consistently.
Support Regulatory Preparedness
Well-organised records, clear procedures and documented remediation can help a firm respond more effectively to questions about the arrangements within the scope of a review.
Prioritise Remedial Action
A clear findings report can help management distinguish between immediate issues, control improvements and longer-term actions. A review does not guarantee compliance or prevent regulatory action. Its value depends on the scope, quality of evidence, accuracy of findings and the firm's response to identified issues.
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?
At Acumen Global Compliance, we provide independent Client Money Audit Services backed by deep regulatory expertise and practical compliance solutions
17+ 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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