CASS 15 Safeguarding Oversight: 5 Key Attributes CASS Oversight Officers Need - Vessy Reid ????

In the 2nd edition of JCR Journal for 2025, we speak to Vessy Reid (née Mihovska) about CASS 15 Safeguarding Oversight. Vessy shared her thoughts from a professional services perspective whereas I look from a recruiters viewpoint.

All thoughts and opinions below are our own.

The FCA published consultation paper (CP) 24/20 in the last quarter of 2024. The proposed changes would lead to large-scale change within the sector, with some firms having to upend existing processes and business models to achieve the FCA’s objective: strengthen the safeguarding arrangements.

To achieve this, the FCA has proposed that firms appoint an individual with sufficient skill and authority to oversee operational compliance with the safeguarding requirements of the EMRs, PSRs and CASS 15. This person will also need to report to the firm’s governing body in respect of this oversight. In practice, this would create a line of defence 1.5, as they would sit between Operations and Compliance, where we have seen CASS find its home within investment firms. This person will also end up being the face of safeguarding not just for the regulator but for auditors as well, which makes it all the more important to hire the right person.

All of this comes within the context of industry talent shortages, more than 10 years on from the introduction of PS14/9, as well as an apprehension from payments and e-money firms to start recruiting for this role before the interim rules are published by the FCA.

Below we set out 5 key criteria for an effective CASS Oversight Officer – along with other factors payment firms and e-money institutions need to consider on their transition ahead of the new CASS 15 rules being published later this year.

Technical Experience

As there will be an implementation period for firms to operationalise the change in rules, the oversight function needs to be led by an individual who has hands-on experience in creating, operating or auditing safeguarding processes and controls.

The experience of individuals within oversight functions tends to be based on a high-level understanding of regulations, focusing on risks and governance, but lacking the in-depth pernickety level of CASS knowledge typical for a technical specialist. Now, that is not to say that a person with the higher-level knowledge can’t do a great job!

Awareness of any technical blind-spots is needed however so that they can get the correct support from someone with sufficient CASS knowledge. There is value in both!

Attitude

Technical skills are important, but they need to be accompanied by the right attitude towards safeguarding.

CASS and safeguarding are the responsibility of everyone within firms and it is important that this message is spread far and wide – from IT through to onboarding and reconciliations teams. An effective oversight function will strike a balance between accountability and a culture of no-blame – where finding solutions is prioritised. On the one side, if an environment is too punitive, people are less likely to come forward when issues arise, leading to greater problems down the line.

On the other, if there is no accountability, this will lead to falling standards and erode the importance of safeguarding. Striking the right balance is challenging even for seasoned leaders.

Creativity & Pragmatism

When it comes to compliance with regulation, especially one as detailed as CASS, the words cost and burden come to mind. If firms have a team of creative and pragmatic individuals, who can translate the regulation into practical solutions for operations teams, this doesn’t need to be the case.

Firms need someone who can map existing processes to the new regulation and in so doing identify the gaps that need to be filled with new processes or enhancements to existing ones.

A great CASS Oversight Officer should also be fluent in the language of the operations function. This will aid engagement with a critical partner, making the transition smoother and avoiding operations becoming overly complex or burdensome in the long run.

Failure to do so will increase the risk of non-compliance. This will either be driven by the sheer number of extra activities that are added to operations each day or complacency due to lack of buy-in from operations. One is driven by non-sustainability of activities and resource-stretch and the other by lack of understanding as to why these activities are required and as such people end up by-passing them. Ultimately, both result in a larger number of breaches.

Communication & Advocacy

A good CASS Oversight Lead should be able to advocate for the proper implementation of safeguarding requirements. They will need to get buy-in from operations by involving them early on and investing in their training to enable them to understand why safeguarding is important, how it flows through processes and the consequences of getting it wrong.

The person in charge of oversight should also be a good advocate for their teams supporting safeguarding. This will take shape in ensuring sufficient resources are provided to enable them to meet the FCA’s high standards for safeguarding. This includes getting the right people in the right places, as well as the appropriate technology solutions, which will enable scalability and compliance to go hand in hand.

Good Grasp of Automation & Change Management

As payment and e-money firms operate in an environment with a high volume of transactions and repetitive tasks, most firms have focused on optimising their operations through automation. As such, the oversight function needs to also speak fluent technology, understand how it currently works and what changes need to be made in order to achieve end state compliance.

Moreover, the changes proposed to the safeguarding requirements are not insignificant, with some requiring changes of business models as well as a full change of how things are currently operationalised. As such, this will be a huge change management undertaking and experienced hands, who are able to anticipate issues in advance and resolve ones that were not predicted as these arise in the initial stages of the migration, are needed.

Worthwhile Consideration: Shortage of CASS Talent

When the FRC Assurance Standard was introduced in 2015, the demand for senior CASS professionals far outweighed the supply and 10 years on, there is still a shortage of talent. Salaries in CASS have gradually increased prompting firms to exceed their usual salary bands to attract the best talent available. For those who haven't recruited heavily in CASS before, this may come as a surprise when entering the market.

A huge thank you to Vessy for her insight into CASS 15 Safeguarding??

If you're looking for external support from a specialist in Safeguarding, feel free to contact Vessy Reid (née Mihovska) at Bovill Newgate

Are you looking to strengthen your CASS expertise? We've recruited in CASS since 2016 and have an excellent talent pool of CASS experts. DM James Carter at JCR Talent ? Your Expert Partner for Regulatory Compliance Recruitment?? for more info

jcrtalent.com ??