“The people must have ownership in the vision. They need to be enabled to accomplish it. If there is one investment you should make, it is in people.”
Modesta Lilian Mbughuni
In 2025, as financial regulation becomes more complex, compliance is now a competitive differentiator. Understanding the Financial Conduct Authority’s (FCA) CASS rules is essential for UK firms that handle client money. One of the more recent additions to this framework is CASS 15.
CASS 15 is pivotal in client asset protection, particularly for payments, e-Money and credit union firms. Learning how it impacts recruitment and team building is a priority. This article is for compliance leaders, HR professionals, and hiring managers who want to understand why it matters and how they can recruit these specialists.
What is CASS 15?
CASS 15 is the latest chapter in the FCA’s Client Assets Sourcebook. It focuses on client money held by payments and e-money firms. The FCA brought these new rules in to strengthen industry protections in case of firm insolvency. It sets out how firms must handle, segregate, and account for money received from or held for clients.
Previous chapters, like CASS 5, 6 and CASS 7, applied to investment and insurance firms. CASS 15 applies to firms managing client funds in the context of payments and e-money solutions. It includes rules and regulations around:
- Reconciliation
- Record Keeping
- Reporting and Resolution Packs
- Governance, risk and control management
CASS 15 has more prescriptive safeguarding rules. It replaces previous guidance and has stricter procedures for protecting consumer funds. This shift from guidance to enforceable rules necessitates specialised roles to ensure compliance.
From your point of view, knowing what CASS 15 is is not a regulatory box-ticking exercise. It’s an integral part of safeguarding client trust. That means you must have the right talent to oversee and put in place the requirements.
Why CASS 15 Matters to Payments and E-Money Firms
Safeguarding helps to protect consumers so that if a firm fails, consumers receive the maximum value of their funds as quickly as possible. According to a consultation paper by the FCA in September 2024,
“For firms that became insolvent between Q1 2018 and Q2 2023, there was an average shortfall of 65% in funds owed to clients (difference between funds owed and funds safeguarded).”
This statistic shows the real-world consequences of inadequate safeguarding and emphasises the need for businesses to manage risk competently. CASS 15 is a big deal when it comes to compliance. Non-compliance with FCA CASS rules can lead to regulatory intervention.
Firms that fail to segregate or reconcile client money don’t just risk fines. It also breaches the trust of the clients you should be serving. It provides greater transparency and protection for consumers in vulnerable financial positions.
With CASS 15, the FCA expects firms to go beyond minimal compliance. The regulator wants firms to focus on having robust, auditable oversight functions. This required oversight is only possible when you have the right talent. That’s where your recruitment prowess and strategic mindset come into action.
What Talent Do You Need For CASS 15 Compliance?
The new rules introduce resource vs requirement and the need to perform daily internal and external reconciliations. To honour this, organisations must use meticulous and dedicated compliance personnel. This type of talent will be comfortable managing increased operational demands.
Financial firms should always seek to recruit the best compliance specialists, employees who can design, track, and improve their clients’ money processing systems. A proactive approach to CASS 15 compliance is a must.
CASS 15 Compliance Talent
Meeting CASS obligations requires companies to have a combination of employees that have:
- Operational/Reconciliations precision
- Deep Technical CASS knowledge
- Excellent Stakeholder and Business communications
- Technological and innovative
Here are three examples of key roles for CASS 15:
- CASS Oversight Officer
This person ensures adherence to the rules and regulations and is often part of the leadership team. They will provide robust governance practices and oversee the critical day to day processes as well as manage the audits and interactions with the regulator.
- Reconciliations Specialist
This employee is highly analytical, able to work with large volumes of transactions and data sets. Understanding the flow of cash through the various business processes and ensuring daily operations for client fund segregation and internal record-keeping.
- Business Analyst (CASS focus)
This role will be key for clients at the early stages of understanding their CASS footprint. They can provide the detailed gap analysis against the CASS 15 rules and create the best blueprints to work toward CASS compliance.
These professionals hold or work towards certifications like ICA qualifications or CISI Risk & Compliance diplomas or have hands-on experience implementing CASS frameworks. The difference here is that CASS 15 specialists must have specific technical knowledge. This hiring is more specialist than recruiting for broader compliance roles.
How to Hire for CASS 15: Key Challenges and Considerations
These roles are not for wallflowers. It’s vital to hire individuals skilled in compliance. These employees must also be proactive in communication and issue resolution. Without people with this skill set, you could become unstuck.
Also, it is imperative to consider your obligations to the FCA. For example, if you can’t perform reconciliations or your internal records are inaccurate. You must inform the FCA of your company’s situation.
How Kohort Recruitment Supports CASS 15 Hiring
Hiring the right talent is imperative to avoid regulatory issues. At Kohort Recruitment, we are experts in helping financial firms secure CASS 15 talent. It’s not easy, and that’s why not everybody does it. As you already know, it’s a specialised market that can make recruitment feel like a burden.
We have years of experience hiring for CASS roles and a specialised talent pool that we have nurtured over time.
Focusing on Employee Retention for Operational Resilience
CASS 15 talent is hard to find. You are looking for candidates who have the prerequisites of experience and qualifications. But we also go the extra mile to match candidates with clients. There is no point in putting forward candidates who will not work in the long term.
We help with employee retention and find candidates to boost operational resilience. We understand that hiring into FCA-regulated functions isn’t just about matching CVs. It’s about placing individuals who can protect your business and your clients. Our approach to recruitment involves:
- A network of pre-qualified candidates with proven experience
- Deep industry knowledge to screen for regulatory and operational expertise
- Advisory support for hiring strategies, job descriptions and team structures
Whether you want to build a CASS team from scratch or need to replace a departing oversight officer, we can help you move quickly and confidently.
Conclusion: Don’t Leave Compliance to Chance
Your recruitment strategy must be as sharp as your operational processes. It’s about recognising compliance is only as strong as the people you have working for you. You can start to build or strengthen an existing team to meet CASS 15 requirements. It will also help to improve your reputation in the industry.
The FCA is now engaging with firms to ensure CASS 15 compliance. The FCA expects transparent governance, practical reconciliation, and proactive monitoring. This increased oversight will only increase. You can deliver this with a proactive recruitment strategy. It will help you to build a team that meets regulatory expectations.
Need help sourcing CASS 15 talent in the UK? Kohort Recruitment is ready to support you. Reach out today for a consultation or candidate shortlist.
Sources:
- CASS Rules – Financial Conduct Authority (FCA)
- FCA Client Assets Sourcebook
- Changes to the Safeguarding Regime – Consultation Paper from the FCA
- How to Fill Compliance and Risk Management Jobs Easily – Kohort Recruitment
- ROI of Talent: Measuring the True Value of Your Operational Resilience Team – Kohort Recruitment