
Business Issue
An investment manager had failed to implement adequate arrangements to protect client assets, creating a risk of harm to clients and compromising the safeguarding of client money and assets.
Solution
To address these issues, the investment manager needed to remediate audit findings and enhance its operating model, controls, and practices to meet regulatory obligations under CASS and maintain its ability to serve clients. We conducted an immediate assessment of their CASS compliance and operating model. A detailed remediation plan was developed, focusing on audit findings and regulatory enforcement areas. We established clear workstreams, defined responsibilities, and set deliverables in alignment with firm executives, the board, and the regulator.


Benefits
The firm was able to implement a structured and timely remediation program, addressing identified weaknesses and ensuring compliance. Our approach provided clarity, accountability, and measurable progress against regulatory expectations.
Client
Feedback
The client valued our hands-on governance and oversight throughout the change programme. They particularly appreciated our support in business readiness and outcomes assessment, as well as the post-s166 delivery phase. The ongoing CASS coaching, training, and mentoring we provided across the business helped embed sustainable practices for long-term compliance.