FCA CASS fines tracker: every client money and custody asset penalty since 2010

Key takeaways

• About £242 million in CASS-related financial penalties since 2010, of which three cases (BNY Mellon, Barclays 2014 and J.P. Morgan Securities) account for £197 million.
• The rules cited most often are the daily internal client money reconciliation (CASS 7.6.2R, now 7.15.12R and 7.15.20R), the trust acknowledgement letter for client bank accounts (CASS 7.8.1R, now 7.18.2R), the custody asset record and reconciliation rules (CASS 6.5) and the CASS resolution pack (CASS 10).
• Insurance intermediaries are fined under CASS 5: One Call (£684,000, 2018) and Towergate (£2.63 million, 2016) both involved client money shortfalls above £12 million.
• No firm has been fined for a CASS breach since Charles Schwab UK in December 2020; the FCA's 2021, 2022, 2023 and 2024 fines tables contain no CASS entry.
• The WealthTek failure produced three outcomes in 2025 and 2026: Barclays Bank UK fined £3.09 million under Principle 3, and Sapia Partners and CACEIS Bank publicly censured with voluntary payments of £19.6 million and £31.7 million to WealthTek clients.
• Eleven individuals have been fined or banned in these cases, from compliance officers who did not understand the rules to a financial controller who falsified reconciliations.

What this tracker covers

This page lists every published FCA and FSA enforcement outcome, from 2010 to today, in which breaches of the Client Assets Sourcebook (CASS) or the client-money principle (Principle 10) were at the centre of the case. CASS is the part of the FCA Handbook that tells investment firms, banks acting as custodians, platforms, brokers and insurance intermediaries how to keep client money and client assets separate from their own, reconcile them and record them. The figures, breach periods and rule numbers come from the final notice in each case, linked in every entry.

The list covers fines on firms, fines and bans on individuals, and public censures (a published finding with no financial penalty). It also records the two cases in 2025 and 2026 where a client money failure at another firm led to a penalty under the systems and controls rules rather than CASS, because those outcomes are part of how the FCA now polices client money. Cases where premiums were simply stolen and no CASS rule was cited are left out.

Payment and e-money firms are not in this list: their customer money sits under the safeguarding rules, which moved into CASS 15 on 7 May 2026 and have produced one censure and no fines. They are tracked separately in the FCA safeguarding enforcement tracker. For the rules themselves see the CASS 7 client money guide and the CASS 6 custody guide.

The totals by year

Financial penalties in CASS-centred cases, by year of the final notice, set against the FCA's published total for all fines that year. The FCA has published annual fines tables since 2013; the FSA years are summed from the notices.

The ten largest CASS fines

Pre-discount figures are the amounts the notice states before the 30% reduction for settling at the first stage, where the notice gives one.

Cases from 2020 to 2026

Six years in which the FCA fined one firm under CASS and handled the WealthTek collapse through the firms around it: the custodian, the bank and the principal firm.

• 19 Jun 2026. CACEIS Bank, UK branch (custodian). As sub-custodian to WealthTek, the bank saw three times on the FCA register that WealthTek had no custody permission and could not hold client money, yet opened and kept the client accounts and left monitoring alerts unresolved between October 2020 and April 2023. Outcome: Public censure with a voluntary payment of £31,714,068 to WealthTek clients; the fine would otherwise have been £23,091,900 (pre-discount £32,988,540). Principle 2; SYSC 6.1.1R, 6.3.1R and 6.3.3R. No CASS rule cited. Source: Final notice (PDF) and press release.
• 20 Apr 2026. Sapia Partners LLP (wealth manager, principal firm). Held client money for its appointed representative WealthTek but allowed WealthTek staff both to make payments from the client money accounts and to perform the reconciliations, with no separation of duties, from January 2014 to October 2020. Outcome: Public censure with a voluntary payment of £19,637,950; the fine would otherwise have been £7,412,000 (pre-discount £10,588,600). Principle 10; CASS 7.3.2R to 31 May 2015 and CASS 7.12.2R from 1 June 2015; SYSC 5.1. Source: Final notice (PDF) and press release.
• 14 Jul 2025. Barclays Bank UK PLC (bank). Opened and kept a client money account for WealthTek, into which about £34 million was paid, between January 2021 and April 2023, without checking the FCA register, which showed WealthTek could not hold client money. Outcome: Fine £3,093,600 (pre-discount £4,419,500). Principle 3; SYSC 6.1.1R. No CASS rule cited. Source: Final notice (PDF).
• 6 Aug 2024. MacIntyre Hudson LLP, MHA (auditor). Four CASS audit reports for two client firms between July 2015 and May 2019 fell below the required standard and omitted 25 CASS breaches, including firm assets held alongside client assets. Outcome: Public censure under section 345 of the Financial Services and Markets Act 2000, no fine. SUP 3.10.4AR(1) breached; underlying client-firm breaches across CASS 6.2, 6.6, 7.10, 7.11, 7.12, 7.13, 7.15, 7.16 and 7.18. Source: Final notice (PDF) and press release.
• 21 Dec 2020. Charles Schwab UK Limited (broker). Between August 2017 and April 2019 the firm had no records or reconciliations identifying client assets, no CASS resolution pack, held client assets for seven months without the safeguarding permission and gave the FCA an inaccurate statement about auditor confirmation. Outcome: Fine £8,963,200 (pre-discount £12,804,600), of which £709,800 for acting without permission. Principles 10 and 11; CASS 6.2.2R, 6.6.2R, 6.6.11R, 6.6.14R, 6.6.34R, 7.12.2R, 7.15.2R, 7.15.12R, 7.15.20R, 10.1.1R, 10.1.3R; section 20 FSMA. Source: Final notice (PDF) and press release.

Cases from 2014 to 2018

The period of the largest fines, and of the CASS 5 insurance intermediary cases.

• 30 Aug 2018. One Call Insurance Services Limited (insurance intermediary). Between January 2005 and September 2014 the firm used premium money as working capital, leaving a client money shortfall of about £17.3 million. Outcome: Fine £684,000 (pre-discount £977,147) plus a 90-day ban on charging renewal fees. Principle 10; CASS 5.5.3R, 5.5.5R, 5.5.63R. Source: Final notice (PDF).
• 30 Aug 2018. John Lawrence Radford (director, One Call). Did not understand or enforce the CASS 5 client money rules, contributing to the £17.3 million shortfall. Outcome: Fine £468,600 (pre-discount £669,531) and a ban from responsibility for client or insurer money. Principle 10; APER; CASS 5. Source: Final notice (PDF).
• 7 Apr 2017. Lukhvir Thind (financial controller, WorldSpreads). Falsified client money reconciliations and the data given to auditors between June 2010 and March 2012, hiding a shortfall of about £15.9 million before the spread-betting firm collapsed. Outcome: Fine £105,000 (pre-discount £150,000) and a full prohibition. Market abuse provisions and fitness; CASS referred to generally. Source: Final notice (PDF).
• 7 Apr 2017. Niall O'Kelly (chief financial officer, WorldSpreads). Falsified accounts and concealed the client money shortfall between July 2007 and March 2012. Outcome: Fine £11,900 (reduced from £468,756 for hardship) and a full prohibition. CASS 7.3.1 and 7.4.1 referenced. Source: Final notice (PDF).
• 5 Oct 2016. Aviva Pension Trustees UK Ltd and Aviva Wrap UK Ltd (platform). Between January 2013 and September 2015 the firms outsourced client money and asset work to third-party administrators without adequate oversight; under-segregation peaked at £74.4 million, monthly returns were inaccurate and the resolution pack inadequate. Outcome: Fine £8,246,800 (pre-discount £11,781,262). Principles 3 and 10; CASS 6.2, 6.5, 6.6, 7.12.2R, 7.15.3R, 7.13.58R, 7.15.18R, 10.1.3R; SUP 16.14.3R (CMAR); SYSC 8. Source: Final notice (PDF) and press release.
• 13 Jul 2016. Towergate Underwriting Group Limited (insurance intermediary). Weak controls between June 2005 and December 2013 let a £12.6 million client and insurer money shortfall build unnoticed, £10.5 million of it from transfers to a parent company's office account. Outcome: Fine £2,632,000 (pre-discount £3,760,000). Principles 3 and 10; CASS 5.5.3R, 5.5.63R, 5.5.76R, 5.5.84R. Source: Final notice (PDF) and press release.
• 13 Jul 2016. Timothy Duncan Philip (client money officer, Towergate). Approved £10.5 million of withdrawals between August 2010 and June 2012 without following the client money processes. Outcome: Fine £60,000 (pre-discount £85,818) and a ban from responsibility for client or insurer money. APER; Principles 3 and 10. Source: Final notice.
• 9 May 2016. Terence Andrew Joint (director, Joint Aviation Services, insurance intermediary). Failed to oversee the firm's finances between April 2011 and June 2012; client premiums were misused and mixed with another entity's funds. Outcome: Fine £10,000 and a prohibition from significant influence functions. APER; CASS referred to generally. Source: Final notice.
• 1 Feb 2016. Coverall Worldwide Ltd (insurance intermediary). Its appointed representative bound insurance without authority and mishandled premiums between December 2010 and September 2013; the firm failed to supervise. Outcome: Fine £36,800 (pre-discount £52,700, reduced for hardship from £471,638) and permission cancelled. Principles 1, 3 and 10; CASS 5.5.3R, 5.5.5R, 5.5.19R, 5.5.21R, 5.5.23R, 5.5.34R, 5.5.80R. Source: Final notice.
• 1 Feb 2016. Colin J McIntosh (Coverall and Millburn). Failed to oversee the appointed representative and misled the regulator about a reinsurance treaty. Outcome: Fine £51,600 (pre-discount £73,949) and a full prohibition. APER; CASS 5.5. Source: Final notice.
• 1 Feb 2016. Robert John Bygrave (Aderia). Did not check whether premiums were client money and paid out on the instructions of an unapproved person between July and September 2013. Outcome: Fine £37,400 (pre-discount £53,400) and a prohibition from significant influence functions, revoked 29 May 2025. APER; CASS 5.1 and 5.5. Source: Final notice.
• 14 Apr 2015. Bank of New York Mellon London Branch and BNY Mellon International Ltd (custodian). Between November 2007 and August 2013 the global custody platforms did not record which group entity each client contracted with, so entity-level reconciliations, resolution packs and monthly returns were wrong; custody assets were mixed with the bank's own in 13 accounts and used from omnibus accounts without consent. Outcome: Fine £126,000,000 (pre-discount £180,000,000). Principle 10; CASS 6.2.2R, 6.3.1R, 6.4.1R, 6.5.1R, 6.5.2R, 6.5.6R, 6.5.10R, 7.4.10R, 7.6.1R, 7.6.2R, 7.6.7R, 7.6.8R, 7.6.9R, 10.1.1R, 10.1.3R, 10.3.1R; SUP 16.14.3R. Source: Final notice (PDF) and press release.
• 9 Oct 2014. Pritchard Stockbrokers Limited, in special administration (broker). Between July 2010 and February 2012 the firm relied on an undocumented offshore overdraft to cover client money shortfalls and used client money for expenses; about £3 million was lost. Outcome: Public censure; a fine of £4,932,600 was reduced to nil because of the firm's financial position. Principles 1, 2 and 10; CASS 7.4.20G, 7.4.21R, 7.6.1 to 7.6.16. Source: Final notice (PDF) and press release.
• 9 Oct 2014. David Welsby and David Gillespie (finance director and managing director, Pritchard). Treated an unverified £2 million overdraft as client money and failed in oversight. Outcome: Fines £14,000 and £10,500 (each reduced for hardship from £72,000 and £144,000) and bans. APER; Principle 10; CASS 7.4.1, 7.6. Source: Welsby notice (PDF) and Gillespie notice (PDF).
• 23 Sep 2014. Barclays Bank plc (bank). Between November 2007 and January 2012 the investment bank held £16.5 billion of clients' custody assets in 95 sub-custodian accounts with incomplete records, agreements, account naming and lien protections, and no reconciliation. Outcome: Fine £37,745,000 (pre-discount £53,921,619). Principles 3 and 10; CASS 1A.2.8R, 6.2.1R, 6.2.2R, 6.3.1R, 6.5.1R, 6.5.2R, 6.5.6R; SYSC 4.1.1R, 6.1.1R. Source: Final notice (PDF) and press release.

Cases from 2010 to 2013

The FSA's client money campaign, which began with J.P. Morgan Securities in 2010 and ran through the first FCA notices in 2013.

• 25 Nov 2013. SEI Investments (Europe) Limited (platform). Between November 2007 and October 2012 the firm missed daily reconciliations, did not fund shortfalls the same day, used an unapproved method and filed inaccurate returns; one untrained employee manually cut a £14 million requirement to £932,000. Outcome: Fine £900,200 (pre-discount £1,286,000). Principle 10; CASS 7.6.2R, 7.6.7R, 7.6.8R, 7.6.13R, 7.6.16R. Source: Final notice (PDF).
• 2 Sep 2013. Aberdeen Asset Managers Ltd and Aberdeen Fund Management Ltd (asset manager). Between August 2008 and August 2011 the firms wrongly decided that money market deposits averaging £685 million a day were outside the client money rules, so there were no trust acknowledgement letters and account names were inconsistent. Outcome: Fine £7,192,500 (pre-discount £10,275,000). Principles 3 and 10; CASS 7.1.1R, 7.3.1R, 7.3.2R, 7.6.1R, 7.6.2R, 7.8.1R. Source: Final notice.
• 31 May 2013. Xcap Securities PLC (broker). Between June 2010 and August 2011 client money and assets were not separated from the firm's own, records were inaccurate, reconciliations were not properly done, trust letters were missing and interest was not paid. The first fine under the FCA's new penalty regime. Outcome: Fine £120,900 (pre-discount £151,136). Principles 3 and 10; CASS 6.2, 6.3, 6.5, 7.2, 7.3, 7.4, 7.6, 7.8. Source: Final notice (PDF).
• 11 Sep 2012. BlackRock Investment Management (UK) Limited (asset manager). After an acquisition, trust acknowledgement letters were not obtained for money market deposits between October 2006 and March 2010; about £1.36 billion a day was unprotected for three and a half years. Outcome: Fine £9,533,100 (pre-discount £13,618,800). Principles 3 and 10; CASS 7.8.1R, 7.3.2R and the predecessor CASS 4 rules. Source: Final notice (PDF).
• 29 Mar 2012. Christchurch Investment Management Limited and David Thornberry (wealth manager and its compliance officer). Between November 2007 and March 2011 there were no daily internal reconciliations, no proper external reconciliations and no trust status letters, with one person overloaded with client money duties. Outcome: Fines £26,600 (firm) and £11,550 (individual, with a ban from compliance oversight). Principles 3 and 10; CASS 7.3.2R, 7.4.11R, 7.6.1R, 7.6.2R, 7.6.7R, 7.6.8R, 7.6.9R, 7.6.13R, 7.6.14R, 7.8.1R. Source: Firm notice (PDF) and Thornberry notice (PDF).
• 5 Dec 2011. Integrated Financial Arrangements plc, Transact (platform). For over eight years to June 2010 the platform did not check daily that the client money it held covered what it owed; shortfalls went unfunded and some clients' money was used for others' transactions; trust paperwork was deficient. Outcome: Fine £3,500,000 (pre-discount £5,000,000). Principles 3 and 10; CASS 4.3 and 7.3, 7.6, 7.8. Source: Final notice (PDF).
• 15 Nov 2011. McInroy and Wood Limited (wealth manager). No written trust confirmation from the bank for 22 offshore client accounts between May 2006 and August 2010. Outcome: Fine £15,050 (pre-discount £21,500). Principle 10; CASS 4.3.48R, 4.3.49R, 7.8.1R. Source: Final notice (PDF).
• 14 Sep 2011. Towry Investment Management Limited (wealth manager). Inaccurate and late client money calculations and reconciliations from 2001 to 2011, followed by a clean CASS confirmation sent to the FSA without checking. Outcome: Fine £494,900 (pre-discount £707,000). Principles 10 and 11; CASS 4.3.66R, 4.3.111R, 7.3.1R, 7.6.1R, 7.6.2R, 7.6.13R. Source: Final notice (PDF).
• 15 Mar 2011 and 9 May 2011. ActivTrades Plc and David McGrath (foreign exchange broker and its compliance officer). Between April 2009 and September 2010 the firm mixed client and firm funds, reconciled inaccurately and infrequently, and kept client interest; the compliance officer lacked CASS knowledge. Outcome: Fines £85,750 (firm, pre-discount £122,500) and £3,000 (individual, reduced for hardship from £20,000, with a prohibition). Principles 3 and 10; CASS 7.2.14R, 7.2.19R, 7.4.7R, 7.4.10R, 7.4.11R, 7.6.1R, 7.6.2R, 7.6.9R. Source: ActivTrades notice (PDF) and McGrath notice (PDF).
• 24 Jan 2011. Barclays Capital Securities Limited (broker). For eight years to December 2009, sterling client money was swept each morning into the corporate account for five to seven hours before being re-segregated; the FSA was told two and a half months after discovery. Outcome: Fine £1,127,559 (pre-discount £1,610,799). Principle 10; CASS 7.4.11R, 7.3.2R and the predecessor rules. Source: Final notice (PDF).
• 4 Jun 2010. Rowan Dartington and Co Limited (stockbroker). Between May 2007 and September 2009 records were inaccurate, reconciliations failed and trust acknowledgements were missing. Outcome: Fine £511,000 (pre-discount £730,000). Principles 2 and 10; CASS 7.4.1R, 7.6.1R, 7.6.2R, 7.6.9R, 7.6.13R, 7.6.14R, 7.8.1R, 7.8.2R. Source: Final notice (PDF).
• 4 Jun 2010. Close Investments Limited (fund manager). For two years to January 2010, 21 distribution accounts were not segregated with trust status. Outcome: Fine £98,000 (pre-discount £140,000). Principles 3 and 10; CASS 7.3.2R, 7.8.1R. Source: Final notice (PDF).
• 25 May 2010. J.P. Morgan Securities Ltd (investment bank). Between November 2002 and July 2009, futures and options client money was held at the group bank in unsegregated accounts. Outcome: Fine £33,320,000, set at 1% of the average unsegregated balance of about US$8.55 billion. Principle 10; CASS 7.4.11R, 7.4.1R and the predecessor rules. Source: Final notice (PDF).
• 21 May 2010 and 22 Apr 2010. Adrian Shillaker and Delwyn Way (insurance intermediaries). Each used client premium money for business or personal spending and misled the FSA or filed inaccurate returns. Outcome: Shillaker: no fine for hardship (£70,000 otherwise) and a full prohibition, CASS 5.5 cited. Way: fine £77,957 and a full prohibition under the integrity principles. Source: Shillaker notice (PDF) and Way notice (PDF).

The rules the FCA cites most

The same handful of rules appears in notice after notice. Rule numbers changed in June 2015 when CASS 7 was renumbered; both are shown.

Supervisory notices with client money findings

A supervisory notice records requirements the FCA has imposed on a firm; it is not a fine, but it often sets out client money failings in detail. Two are relevant.

• 16 Mar 2023. CFS Management Ltd (investment firm). £10.09 million of client money was not segregated. Outcome: First Supervisory Notice imposing requirements. CASS 7.13.3R, 7.13.6R, 7.13.12R, 7.18.2R; Principles 3 and 10. Source: Supervisory notice (PDF).
• 28 Jan 2015. LQD Markets (UK) Ltd (broker). Client money frozen and a primary pooling event declared, with a shortfall of up to US$2.03 million. Outcome: Supervisory notice. CASS 7.6.1R, 7.6.2R, 7.6.9R, 7.6.13R, 7A.2.2R. Source: Supervisory notice (PDF).

What the pattern shows

The fines fall into two kinds. The large ones (BNY Mellon, Barclays, J.P. Morgan, BlackRock, Aberdeen) were not about missing money: they were about records, entity-level reconciliations and trust letters at firms that held billions and would have struggled to return it quickly in an insolvency. The small ones (One Call, Towergate, Pritchard, WorldSpreads) were about real shortfalls, found late, at firms that had been using client money as working capital.

Since 2020 the FCA has moved its attention to the firms around a failure. The WealthTek outcomes punished the bank that opened the account, the custodian that held the assets and the principal that let the reconciliations be done by the firm being reconciled. The lesson for any firm holding client money is the same one the notices have repeated since 2010: reconcile every day, fund the difference the same day, hold the trust letters, keep the resolution pack current and have someone independent check the work.

Safeheld reconciles client money every business day for regulated firms, works every difference to its cause and keeps the record auditors ask for, and is extending that work to CASS 6 and CASS 7. If your firm holds client money or custody assets under CASS, talk to us about CASS.

Frequently asked questions

What is the largest FCA fine for client money breaches?

£126 million, imposed on Bank of New York Mellon London Branch and BNY Mellon International in April 2015 for custody asset and client money record-keeping and reconciliation failures over nearly six years. The pre-discount figure was £180 million.

How much has the FCA fined firms for CASS breaches in total?

About £242 million between 2010 and October 2026 in cases where client money or custody asset failures were at the heart of the final notice, plus a £3.09 million fine on Barclays Bank UK in 2025 under the systems and controls rules for opening a client money account for WealthTek.

When was the last FCA fine for a CASS breach?

Charles Schwab UK, fined £8,963,200 on 21 December 2020. Since then the FCA has issued three public censures (MacIntyre Hudson in 2024, Sapia Partners and CACEIS Bank in 2026) and one Principle 3 fine (Barclays Bank UK, 2025), none of them a CASS fine on the firm that held the money.

Which CASS rule is breached most often?

The daily internal client money reconciliation, CASS 7.6.2R before June 2015 and CASS 7.15.12R and 7.15.20R since, appears in more notices than any other rule, followed by the trust acknowledgement letter requirement (CASS 7.8.1R, now 7.18.2R).

Do insurance brokers get fined under CASS?

Yes, under CASS 5. Towergate Underwriting was fined £2.63 million in 2016 for a £12.6 million client and insurer money shortfall, and One Call Insurance Services £684,000 in 2018 for a shortfall of about £17.3 million, with their responsible individuals fined and banned.

Are payment and e-money firms in this list?

No. Their customer money falls under the safeguarding rules, now CASS 15, which have produced one public censure (Premier FX, 2021) and no fines. Those cases are in the separate FCA safeguarding enforcement tracker.

How often is this tracker updated?

It is reviewed whenever the FCA publishes a final notice, decision notice or supervisory notice mentioning client money, client assets or CASS, and the review date at the top of the page is updated each time.

References

• FCA, Final Notice: Bank of New York Mellon London Branch and BNY Mellon International, 14 April 2015
• FCA, Final Notice: Barclays Bank plc, 23 September 2014
• FCA, Final Notice: Charles Schwab UK Limited, 21 December 2020
• FCA, Final Notice: Sapia Partners LLP, 20 April 2026
• FCA, Final Notice: CACEIS Bank UK Branch, 19 June 2026
• FCA, 2025 fines

About Safeheld

Safeheld reconciles client money every day, resolves every difference and prepares every regulatory return for sign-off, for regulated firms in the United States, the United Kingdom, the European Union, Canada, Australia, Singapore and Hong Kong. To discuss your operations, contact us at safeheld.com/contact.

This tracker is compiled from public primary sources for general information and does not constitute legal or regulatory advice. Figures are as stated in the source documents and may be revised by the courts, the administrators or the FCA.