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CASS 15 Safeguarding for Payment and E-Money Firms: Practical Implementation under PS25/12 (Part 1)
- 4 CPD Units
- 4 Hours
- Live Online
- 30 April 2026
- 09:30 – 13:30 UK Time
- Live Online
£474.00
This implementation-focused programme provides a structured, practical walkthrough of how PSPs and EMIs can embed compliant safeguarding frameworks. It addresses segregation and insurance safeguarding models, reconciliation processes, shortfall management, reporting obligations and audit preparation. The session draws on emerging supervisory findings across the payments sector and highlights common control failures identified by the FCA.
By the end of the programme, participants will be able to:
- Explain how CASS 15 applies to payment institutions and e-money firms
- Interpret the key safeguarding changes introduced by PS25/12
- Assess the suitability of segregation versus insurance or guarantee methods
- Design proportionate safeguarding governance frameworks
- Implement compliant D+1 reconciliation processes
- Identify and manage safeguarding shortfalls and funding gaps
- Prepare and maintain a compliant Resolution Pack under CASS 10A
- Understand reporting requirements under SUP 16.14A
- Prepare for the independent safeguarding audit under SUP 3A
- Recognise common supervisory failings in the payments sector
The programme combines structured regulatory teaching with practical implementation examples, reconciliation walkthroughs and supervisory case analysis. Participants will apply safeguarding requirements to real world operational scenarios and explore governance and audit readiness considerations through interactive discussion.
The programme is ideal for:
- Compliance and Risk Officers within PSPs and EMIs
- Heads of Operations and Finance
- SMF holders responsible for safeguarding oversight
- Treasury and reconciliation teams handling relevant funds
- Internal Audit and Assurance professionals
- Regulatory advisers to payment institutions
Programme Outline
The CASS 15 Safeguarding Regime for PSPs and EMIs
- Application to relevant funds under PSRs and EMRs
- Supplementary Regime and transition framework
- Supervisory focus and enforcement themes
- Implementation timeline and regulatory expectations
Governance and SMF Accountability
- SMF responsibilities under CASS 15
- Board oversight and attestation expectations
- Safeguarding risk assessments
- Management information and challenge
Segregation and Safeguarding Accounts
- D+1 segregation requirements
- Operation of safeguarding accounts
- Acknowledgement letters and bank confirmations
- Diversification and third-party due diligence
Reconciliations and Operational Controls
- Senior management responsibility for safeguarding
- Oversight of operational safeguarding controls
- Board reporting, MI and attestation
- Safeguarding risk assessments
Safeguarding Methods: Segregation and Insurance
- D+1 segregation requirements
- Safeguarding accounts and acknowledgement letters
- Diversification and third-party risk
- Insurance and comparable guarantee method under CASS 15
- Supervisory concerns around insurance reliance
Reconciliations and Operational Discipline
- Daily internal and external reconciliation expectations
- Break identification and exception handling
- Funding top-ups and shortfall remediation
- Record-keeping and audit evidence standards
Resolution Pack and Reporting Obligations
- CASS 10A Resolution Pack requirements
- Retrieval and maintenance standards
- Monthly safeguarding return under SUP 16.14A
- SUP 15 notification triggers
Independent Audit and Supervisory Scrutiny
- Scope of the safeguarding audit under SUP 3A
- Preparing for reasonable assurance review
- Typical audit findings in PSPs and EMIs
- Remediation planning and control strengthening
Safeguarding Within the Wider Control Framework
- Interaction with SYSC governance
- Outsourcing and safeguarding accountability
- Operational resilience and wind-down planning
Susana Eddy
Susana is a specialist in regulation and governance. She has over 15 years of experience in financial services. Her sector knowledge includes investment management, fintech, and insurance. During her career, she has worked at organisations like Deloitte, BlackRock, FNZ, and NFU Mutual. At these companies, she delivered regulatory oversight, built compliance frameworks, and managed operational risk.
Along the way, Susana has led key regulatory change projects. Additionally, she managed audit and assurance activities. This meant she supported firms in meeting UK regulatory requirements. She has developed and put in place governance structures, introduced oversight processes, and improved risk reporting.
Furthermore, Susana has chaired internal committees and written board reports. She has also supported supplier evaluations as part of regulated procurement. In addition, she has created and delivered training sessions on regulatory topics. She contributed to new policies and procedures. Working closely with both internal and external stakeholders, she has assessed and raised standards of compliance with FCA rules.
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