CASS 15 is going to put Payment Service Providers (PSPs) and Electronic Money Institutions (EMIs) in the spotlight, making safeguarding client funds a priority. Are you 100% ready for CASS 15 and everything it entails? It requires a deep understanding of operational resilience and regulatory alignment. In this article, Kohort Recruitment shares key information to help you find and appoint an effective CASS Oversight Officer for CASS 15.

What does a CASS Oversight Officer do in a PSP or EMI firm?

A CASS Oversight Officer plays a critical role in the firm for PSPs and EMIs. It requires a set of skills that few people have in the industry. An effective role involves using technical CASS experience alongside modern skills. These skills include change management, governance, and CASS training.

CASS Officer Responsibilities Under FCA

Here are some of the core responsibilities of a CASS Oversight Officer:

• The officer must ensure there is daily compliance with the FCA’s CASS regulations.
• The CASS Oversight Officer is responsible for safeguarding client funds at all times.
• Maintains client money reconciliations to ensure a real-time overview is available. 
• Keeps oversight of outsourced processes and functions relating to the protection of client money and safeguarded funds.

Essential Knowledge and Abilities For A CASS Oversight Officer

The CASS Oversight Officer must have specific skills, knowledge and experience to be successful. Here are the areas to consider when you are recruiting for this role:

Translate Regulations Into Operational Processes

A CASS Oversight Officer must be able to translate regulations into operational processes. This oversight also includes monitoring reconciliations and ensuring they are carried out effectively, overseeing key outsourced processes and functions related to client money and safeguarded funds.

The person must ensure the CASS oversight governance framework meets the regulatory requirements. This accountability covers all aspects of the controls, processes, and systems.

For example, it involves the oversight and enforcement of the sourcebook obligation mapping to the CASS sourcebook. Additionally, conducting a second-line review and assessment of control frameworks that mitigate CASS risk.

The Ability To Implement Reporting Procedures

The officer must have a deep understanding of their responsibilities under the FCA. These include everything related to regulatory compliance. Also, maintaining effective oversight and implementing reporting procedures. 

The reporting responsibilities are extensive and include areas such as:

• Being a primary point of contact for annual external CASS and Safeguarding Audits
• The main contact for internal audit programmes for CASS and safeguarding activities
• In charge of incident triage and evaluation
• Regulatory submissions, such as the CMAR
• Breach detection, remediation, and reporting
• Notification events to the regulator

Special Skills CASS Oversight Officers Need

There are also additional skills that these officers require. Without these extra skills, people will struggle in this specialised role. Hiring the wrong person could be detrimental to your business, and trigger long and costly recruitment processes. 

It is therefore essential that you consider the following skills when recruiting. For example, they must have:

• Clarity in decision-making, especially in areas where commerciality and compliance intersect.
• Strong CASS and wider FCA handbook technical expertise and decision-making skills in reconciliations.
• An understanding of how to track client monies from their entry to the exit of the firm’s systems. This tracking must include all the firm’s CASS touchpoints.
• The officer will hugely benefit from experience with CASS 7 and have extensive hands-on experience with CASS reconciliations. If they don’t, they may find it hard to keep pace with regulations under CASS 15. 

If your CASS Oversight Officer does not possess these additional skills, your firm could put your clients at financial risk. These breaches could then lead to serious consequences, including fines from the FCA.

Still getting to grips with CASS 15? Read our recruiters’ guide for Payments and E-Money Firms.

FCA Requirements for Client Fund Safeguarding

If you have identified a candidate who meets all these criteria, that is a strong start. However, to ensure their effectiveness, it is essential that your firm fully understands the FCA’s requirements for safeguarding client funds.

Here are some details to help you understand what the FCA expects from PSP and EMI firms.

The Scope of the Requirements

• Auditability and documentation
• Perimeter Assessment
• Segregation and reconciliation rules
• Timely identification and return of client funds

Safeguarding Requirements for E-Money Firms

• Asset protection in the event of insolvency
• Segregated accounts or insurance-based safeguarding for safeguarding client funds

Expectations from the FCA

• Your firm must have a designated CASS Oversight Officer. This position must be their sole responsibility and role in the organisation.
• You must show evidence of good governance and reporting cycles throughout the organisation.
• Your PSP or EMI firm must have effective risk and control mechanisms in place. Ones that meet the CASS 15 stipulations.
• To ensure CASS 15 compliance, you must also have independent oversight, proactive processes, and conduct regular testing.

Avoiding Common CASS Compliance Failures

Taking steps to avoid common CASS compliance issues is a proactive way to stay compliant. Here are some of the most common CASS compliance failures to be aware of:

1. Delays in breach escalation or rectification
2. Inadequate documentation and reconciliations
3. Weak oversight of third-party payment providers

So, what can the CASS Oversight Officer in your PSP or EMI firm do to stay on top of it all and be as effective as possible? We would recommend that your business do the following straightaway:

• Conduct accurate daily and internal reconciliations
• Use evidence-based monitoring frameworks
• Enact periodic CASS assurance reports

Extra Measures To Stay Effective for CASS Compliance

As soon as possible, start embedding a risk-aware mindset into your business’s culture. It will help you identify and prevent errors. Also, don’t be afraid to dive into automation possibilities. Being adept at change and automation can help your officer mitigate any manual risks.

Best Practices in CASS Oversight for PSPs and EMIs

Starting in the best possible way when it comes to CASS 15 will help you establish the best practices. Here are four areas to pay particular attention to.

1. Technical CASS 7 Experience

We mentioned this earlier in the article, but it is worth noting again how important this is. Hiring CASS Officers with CASS 7 experience should be non-negotiable for your company. Your officer must have this knowledge to be an effective CASS Officer.

2. Invest In These Areas To Stay On Top Of Everything

Use automation tools like Grath | The Intelligent Compliance Platform for both reconciliations and reporting. You can also create governance dashboards and escalation frameworks. 

3. Build Relationships With The VIPS

You must build strong relationships in the industry. For example, push for strong stakeholder management across compliance, finance, and operations. Also, don’t forget to maintain clear communication with your 3rd parties, the auditors and the FCA.

4. Embed CASS Into The Culture

Implementing and maintaining a CASS culture is essential. Additionally, it is crucial to promote good governance for CASS 15 from the top down. It’s about fostering collaboration, not just maintaining control within the business itself. 

The officer can do this by creating and administering CASS and Safeguarding training. It’s also essential for them to oversee materiality thresholds and policy approval.

Find out why CASS 15 recruitment is getting tougher and what you can do about it.

What Sets an Effective CASS Oversight Officer Apart

During the recruitment process, you must select and hire a person who will be the most effective. In summary, their top traits should be:

• Proven technical CASS experience
• Deep technical knowledge of reconciliations
• The ability to navigate FCA CASS Regulations and PSP/EMI environments

The critical soft skills are:

• Stakeholder management
• Strategic thinking and adaptability
• A balanced mindset when it comes to commerciality vs. compliance

Look for candidates who are interested in continuous learning and have technical fluency. A CASS Officer who is adept at change and automation will always give you long-term value.

The Future of Client Funds Under CASS 15

The role of the CASS Oversight Officer will continue to grow in importance in the fintech space. You must learn to hire with intention, rather than finding compliance box tickers.

Your priority as a PSP or EMI firm is to hire governance-driven leaders who are both technically capable and effective. Because effective oversight will protect your clients, satisfy the FCA, and help you build a strong foundation for growth.

We hope that this article helps you understand the role of the CASS Oversight Officer in more detail. If you would like specialised support to source and hire CASS 15 talent, please fill in our quick form here.

Sources: 

1. Is Your Business Truly Resilient? – Kohort Recruitment
2. Client Assets Handbook – Financial Conduct Authority
3. What is CASS 15? A Recruiter’s Guide For Payments and E-Money Firms – Kohort Recruitment
4. Grath – The Intelligent Compliance Platform – Grath
5. Why CASS 15 Recruitment Is Getting Tougher In 2025 – Kohort Recruitment