When Safeguarding Goes Wrong, Who Is Personally Responsible?
The Question Most Boards Haven’t Answered Clearly Payment and e-money firms have spent the past nine months preparing for CASS 15. Policies have been written, auditors engaged, reconciliation processes reviewed. But there is one question that often goes unresolved even in well-prepared firms: if the safeguarding framework fails, who is personally accountable? Not the firm. […]
CASS 15 Is Live: Where Payment Firms Are Already Facing Operational Pressure
The Deadline Has Passed. The Work Has Not. On 7 May 2026, CASS 15 came into force. The FCA’s new safeguarding regime for payment and e-money firms is no longer something to prepare for — it is something firms are now expected to demonstrate compliance with, from day one. For some firms, that is a […]