FCA CASS 15 Readiness Checklist (v1.0)

Firm name

📝 Instructions: You can save your progress at any time and return later to complete the CASS 15 readiness checklist. After submitting, you’ll still be able to make edits if needed. A PDF copy of your submitted checklist will be automatically sent to your e-mail as an attachment.

🔍 This checklist includes over 50 targeted questions to help firms assess whether they are operating within the scope of CASS 15, and to identify further actions needed to achieve compliance. These may include conducting a gap analysis, internal implementation efforts, and considering external support or independent validation.

⚠️ While this serves as a practical tool, it is not a substitute for reviewing the rules themselves, including the additional guidance outlined in the revised Approach Document.

📌 Use this tool as a starting point—but be prepared to seek expert support where needed.

CASS 15.1 Purpose and application

Rows	Yes	No	N/A	Status
Have you documented all of the firm's activities and services and the determination of why they are within the scope of CASS 15?
Have you documented the flow of funds, its sources and destination, and system(s) in which transactions are recorded?
Are there any activities and services which are not in scope of CASS 15? If yes, have you documented why they are not in scope of the rules?
Have you determined that certain funds are not in scope of safeguarding on the basis of PERG 15 territorial scope? If yes, are you satisfied that it is the right basis supported by legal analysis and / or counsel?
For EMIs, do you carry out unrelated payment services? If yes, do you safeguard relevant funds for unrelated payment services separately to relevant funds relating to the issuance of electronic money?

CASS 15.2: Organisational requirements

Rows	Yes	No	N/A	Status
Do you have adequate CASS safeguarding governance arrangement which covers all of the following matters:
a) CASS 15 committee and MI
b) CASS 15 rules, risks and controls matrix
c) CASS 15 policies and procedures
d) CASS 15 incidents and breaches register
e) Monthly safeguarding return to the FCA
f) CASS 10A RP attestation and compliance
g) Qualified auditor selection and appointment
h) CASS 15 safeguarding training

CASS 15.2: Requirement to have adequate oversight

Rows	Yes	No	N/A	Status
Have you appointed a safeguarding oversight officer (or equivalent director or senior manager)?
Have you determined the firm's governing body which the safeguarding oversight officer will report to?

CASS 15.2: Protection of relevant funds

Rows	Yes	No	N/A	Status
Does your relevant funds bank account has the word "safeguarding" included in the naming of the account(s)?
Do you operate another type of bank account(s) to receive relevant funds prior to safeguarding them in a relevant funds bank account? If yes, is the naming of those account(s) appropriate to separately identify them from the relevant funds bank account, and other accounts holding the firm's own funds?
Do you have a system of processes and controls in place to identify relevant funds that are not yet held in a relevant funds bank account?
Is your firm subject to other client money rules, e.g. MiFID activities falling within the scope of CASS 7 rules? If yes, do you have adequate policies and procedures in place to identify and determine under which activity it is holding funds?

CASS 15.2: Allocation of relevant funds receipts

Rows	Yes	No	N/A	Status
Have you determined what is deemed to be "prompt" in the context of allocating relevant funds to an individual client?
Do you have an internal ledger within your system to record "unallocated relevant funds"?
Do you have a system in place to promptly identify, record and allocate relevant funds to a client?
Do you operate internal suspense accounts where relevant funds may be in-transit? If yes, have you identified the nature of the transactions in these suspense accounts?
Do you have an internal ledger within your system to record "unidentified relevant funds"?
Do you have a system of processes and controls in place to return unidentified funds?

CASS 15.3: Segregation method

Rows	Yes	No	N/A	Status
Do you have a written policy for handling mixed remittances and describing the method for identifying the portion which is attributable to the execution of payment transactions?
Do you segregate relevant funds in a different currency from which they were received or liable to the client? If yes, do you adjust the FX each day as part of your internal safeguarding reconciliation?

CASS 15.4: Segregation: secure, liquid assets

Rows	Yes	No	N/A	Status
Does your investment of relevant funds in secure, liquid, low-risk assets meet the definition of the FCA's approved assets?
Have you sought FCA's approval to invest in assets which do not fall within the definition of CASS 15.4.2 G (relevant assets)?
Do you have a secure, liquid assets (relevant assets) policy in place?
Are the redemption of relevant assets paid into a relevant funds bank account?
Where a third party is appointed to manage relevant assets, have you carried out sufficient and appropriate due diligence of the third party in accordance with CASS 15.4.8 to CASS 15.4.12?

CASS 15.6: Selection and appointment of third parties

Rows	Yes	No	N/A	Status
Have you carried out appropriate due diligence of third parties with whom the firm's relevant funds or relevant assets are held?
Have you considered the need for diversification as part of your due diligence?
Does the due diligence focus on the specific legal entity in question, (e.g. Lloyds Bank Plc), rather than the group as a whole (e.g. Lloyds Banking Group)?

CASS 15.7: Acknowledgement letters

Rows	Yes	No	N/A	Status
Do you have complete capture of all third parties and accounts in which relevant funds or relevant assets are deposited or invested?
Have you used the template in CASS 15 Annex 1 to draft your acknowledgement letter which covers all third parties and relevant funds or relevant assets accounts in which they are held?
Do you have processes and controls in place to ensure relevant funds or relevant assets are not deposited or invested into the account until an acknowledgement letter is countersigned and received from the third party?
Have you checked whether an authorised signatory has countersigned the acknowledgement letter?
Do you have processes and controls in place to periodically check (at least annually) that each of the countersigned acknowledgement letter remains accurate?

CASS 15.8: Records, accounts and reconciliations

Rows	Yes	No	N/A	Status
Do you have a safeguarding policy which has been reviewed and approved by the safeguarding officer, and reported to the firm's governing body ?
Do you have a safeguarding reconciliation policy which: a) describes all the matters in CASS 15.8.2 G; b) identifies the key sources of information for the safeguarding resource, Items A to D (CASS 15.8.26 R); c) identifies the key sources of data for the safeguarding requirement, including any additions and deductions (CASS 15.8.30 R to CASS 15.8.34 R); d) identifies the key sources of data for the D+1 comparison (CASS 15.8.35 R); e) describes the system of processes and controls which ensures the completeness and accuracy of the firm's reconciliations; and f) ensures an accurate amount of relevant funds are safeguarded to comply with CASS 15.8?
Are the internal records maintained by the firm separate to those which are provided by or obtained from third parties?
Does the safeguarding oversight officer and the reconciliation team understand the difference between the internal safeguarding reconciliation and the D+1 comparison reconciliation?
Is the firm able to determine and explain the reason for its internal safeguarding reconciliation discrepancy?
Is the firm able to determine and explain the reason for its D+1 comparison reconciliation discrepancy?
Is the firm able to determine and explain the reason for its external safeguarding reconciliation discrepancy?

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FCA CASS 15 - Safeguarding