Client money and client assets are among the most tightly regulated obligations that FCA-regulated businesses carry. The Client Assets Sourcebook (CASS) sets out comprehensive rules for how firms must segregate, reconcile and report on money and assets held on behalf of clients. The accountant or finance professional responsible for the CASS reconciliation process must be both technically competent as a qualified accountant and specifically knowledgeable about the CASS regime — its daily and monthly reconciliation requirements, its record-keeping obligations, the CMAR (Client Money and Assets Return) submission, and the firm’s obligations when a reconciliation break is identified.
Accountancy Capital places CASS-experienced accountants, Client Money Specialists and Client Assets Accountants at FCA-regulated firms across the UK at £50,000 and above. These are roles where the regulatory and technical requirements are sufficiently specific that finding a genuinely capable candidate requires access to a specialist candidate network rather than a generic finance search.
Who Must Comply with CASS
CASS applies to all FCA-regulated firms that hold money or assets belonging to clients in the course of their business. The main CASS provisions are: CASS 5 (client money for insurance intermediaries), CASS 6 (client assets for investment businesses), CASS 7 (client money for investment businesses), CASS 11 (mandate assets). The largest user populations of CASS are investment firms, stockbrokers, discretionary and advisory wealth managers, IFA networks, custodians, fund managers and payments firms with segregated client accounts.
The FCA CASS Sourcebook specifies precisely what records must be kept, when reconciliations must be performed, and what must be reported to the FCA via the CMAR. A failure in the client money reconciliation — an unexplained break, an undocumented shortfall, a missed daily rec — is a regulatory breach with direct FCA notification obligations under SUP 15. These are not administrative failures; they create direct regulatory exposure for the firm and for the individuals responsible for the process.
| Role | London | Notes |
|---|---|---|
| CASS Accountant / Client Money Accountant | £52k–£72k | CASS 5/6/7 operational experience required |
| Senior CASS Accountant | £65k–£85k | Independence over reconciliation + break investigation |
| Head of Client Money / CASS Manager | £75k–£100k | Policy ownership, FCA notification, CMAR preparation |
| Interim CASS Accountant (day rate) | £380–£520/day | Regulatory urgency often drives interim requirement |
Brief a CASS Accountant Search
Accountancy Capital places CASS-experienced accountants and Client Money Specialists at FCA-regulated firms across the UK. Call us before you brief.
Talk to us → or call 0204 553 8893
What a CASS Accountant Actually Does
The day-to-day responsibilities of a CASS accountant centre on the reconciliation cycle. The daily CASS 7 internal reconciliation requires the firm to match its internal records of client money balances to the balances held in segregated client bank accounts — and to investigate and resolve any difference before the end of the business day in most cases. The monthly external reconciliation requires the firm to reconcile client money balances against the external records held by the banks that hold the segregated accounts. Both must be documented, reviewed and retained for FCA inspection.
Beyond the reconciliation cycle, the CASS accountant contributes to the annual CMAR (Client Money and Assets Return) submitted to the FCA via GABRIEL, maintains the firm’s client money policy and records under CASS 7.15–7.19, and works with the CASS Oversight Officer — typically the Head of Compliance or a designated Compliance Manager — on the firm’s client assets monitoring programme. Where a break is found that cannot be explained and resolved on the same day, the CASS accountant typically leads the investigation and works with the Compliance team on the FCA notification if the threshold for mandatory reporting is met.
Qualifications and Background
CASS accountants are typically ACA or ACCA-qualified, with previous experience at a regulated investment firm, custodian or wealth manager where they have been directly responsible for producing client money reconciliations rather than supervising them. The distinction matters: a candidate who has overseen a client money function but has not personally produced the daily and monthly reconciliations will take significantly longer to become independently productive than one who has run the process themselves.
Some CASS specialists have a compliance rather than accounting background — they have come from client assets compliance roles and developed the operational finance capability alongside the regulatory framework knowledge. These candidates are valuable where the firm’s primary need is policy development and regulatory engagement rather than day-to-day reconciliation operations. In most cases, however, the regulated firm needs someone who can run the reconciliation independently and accurately, which requires the qualified accountant profile rather than the compliance route.
FD Capital: Head of Compliance and CASS Oversight Officer
The CASS Oversight Officer or Head of Compliance who has designated responsibility for the client assets regime at board level is typically placed by our sister practice FD Capital, which covers SMF16 and senior compliance appointments at FCA-regulated firms. Accountancy Capital covers the finance and accounting layer: the CASS Accountant, Client Money Specialist and Head of Client Money who manage the operational reconciliation process that sits below the CASS Oversight Officer.
A Note from Our Founder — Adrian Lawrence FCA
CASS is one of the areas where the cost of getting the hire wrong is most visible and most immediate. A qualified CASS accountant who cannot produce an accurate daily client money reconciliation creates a compliance exposure that goes directly to the FCA. I have spoken with CFOs at regulated firms who discovered their CASS process was not being managed correctly only at the point of an FCA supervisory visit or a client complaint — at which point the remediation cost and the regulatory relationship damage are both significantly higher than the cost of hiring the right person in the first instance.
What makes this search difficult is that the pool of candidates who have genuinely run a CASS reconciliation process independently — not supervised it, not assisted with it, but owned it — is smaller than the number of job advertisements that say they need one. Getting to those candidates quickly requires the right network.
Adrian Lawrence FCA
Founder, Accountancy Capital — Qualified finance recruitment specialists, £50,000 and above. Adrian is a Fellow of the Institute of Chartered Accountants in England and Wales — verify via ICAEW.
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Brief a CASS Accountant Search
Accountancy Capital places CASS-experienced accountants and Client Money Specialists at FCA-regulated firms at £50,000 and above. Call 0204 553 8893.
Brief us on your hire → 0204 553 8893 — Mon–Fri 9am–5:30pm