
The FCA is tightening its grip on CASS compliance.
Firms continue to face challenges in meeting the FCA’s elevated standards on CASS. Weaknesses in governance, reconciliation, documentation and oversight remain common — and the regulator is paying close attention.
This isn’t just about new firms. Long-standing businesses once seen as low risk are now under scrutiny. Past performance is no protection if current standards fall short, and the FCA has made clear it’s prepared to act.
Meeting the basics is no longer enough. CASS compliance is now a critical defence against regulatory action.
At Thistle Initiatives, we’ve helped a wide range of firms address CASS audit findings and strengthen their control frameworks. Based on that experience, we’ve created a practical checklist of ten essential steps to help your firm stay compliant and respond confidently to FCA scrutiny.
This guide is brought to you in partnership with Griffin.
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Along with our partner, Griffin, we’ve developed a practical checklist of ten essential steps designed to help your firm remain compliant and respond confidently to the FCA’s increased scrutiny of CASS arrangements.
Manager and CASS Lead
Keith Maner is a seasoned compliance professional and the CASS lead at Thistle Initiatives. With over 20 years of experience in financial services, Keith specialises in helping firms navigate the complex requirements of the FCA’s Client Assets Sourcebook (CASS).
He supports a wide range of clients, from newly authorised firms to established institutions, ensuring their CASS governance, reconciliation processes, and audit preparedness meet regulatory expectations. He is a Fellow of the Chartered Institute for Securities & Investment (FCSI) and a trusted voice on all things CASS.
Partner, Investments
Alex joined Thistle Initiatives in 2015 after two decades of working with complex financial products. Alex's diverse experience in financial services includes roles across front office trading and dealing, management, and consultancy, offering valuable insights into FCA compliance and regulations.
As a former proprietary trader, Alex handled various financial instruments, transitioning from open out-cry to various trading platforms. Additionally, Alex served as a Compliance Business Analyst, supporting multi-asset trading teams. Alex's expertise extends to FCA compliance auditing, oversight, and advisory services on enforcement actions and MIFID audits.
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