The FCA has issued a ‘Dear CEO’ letter to General Insurance Intermediaries setting out its expectations for maintaining adequate arrangements that safeguard client money especially during the coronavirus (Covid-19) pandemic.
It reminds firms of their obligations to continue to oversee the CASS arrangements. It requires firms to discuss the contents of the letter with the board and agree what further action is necessary to help ensure adequate arrangements are in place, highlighting the following areas:
- application of client money rules to firm’s business model;
- governance and oversight;
- oversight of third parties, including due diligence;
- client money calculations and reconciliations;
- acknowledgement letters for all client money accounts.
You can find further information regarding client assets and coronavirus here.
Advising non-UK clients
Alistair MacDougall Compliance Conduct, EEA, email, EU, FCA, MiFID, passport, PI, vulnerable
Despite the fact that the UK ceased to be a member of the EU/EEA almost a year ago, we are still asked for advice around how a UK firm can take on a new non-UK client or continue to deal with such clients that the firm had pre-BREXIT. We have written before about the general […]