Segregate, reconcile and evidence client money across every account, entity and jurisdiction you operate in — with the calculations, controls and audit trail your regulator expects.
Capabilities
From the moment funds arrive to the reconciliation you sign off, Saafehouse operates the controls that keep client money segregated, protected and provably in order.
Process
Architecture
Registers, reconciliation, reporting and a full audit trail all run on one core engine — the same machinery behind both client money and asset operations. Hover a layer to explore it.
Why Saafehouse
| Control | Typical today | With Saafehouse |
|---|---|---|
| Client money calculation | Spreadsheet, run periodically | Automated daily — requirement vs resource |
| Reconciliation | Manual matching, end-of-day | Continuous internal & external, auto-matched |
| Breaches & shortfalls | Found late, remediated ad hoc | Flagged same-day with calculated top-ups |
| Multiple regimes & jurisdictions | A separate process per rulebook | One engine across CASS, SRA & offshore rules |
| Audit & s.166 readiness | Reassembled after the fact | Immutable and always audit-ready |
Use cases
However your obligation arises — CASS, the SRA Accounts Rules, safeguarding under the PSRs and EMRs, or Channel Islands equivalents — the same controls apply. Explore your sector:
Client Account Rule compliance is a persistent area of risk. Shortfalls, delayed reconciliations, improper withdrawals and un-returned residual balances remain a leading cause of SRA enforcement — and once-every-five-weeks reconciliation leaves firms exposed.
A national law firm was fined £160,000 after its client account was not reconciled every five weeks and residual balances sat un-returned for up to seven years.
Source: Legal Futures, “Leading national firm fined £160k for accounts rule breaches”, Apr 2026.
| SRA rule | Requirement | Where Saafehouse fits |
|---|---|---|
| Rules 2 & 4 | Keep client money separate, in a client account distinct from the firm’s own money. | A real-time view of every designated and general client account and balance, with segregation monitored and acknowledgement-letter status tracked. |
| Rules 2.5 & 4.3 | Return client money promptly once there is no proper reason to hold it; manage residual balances. | Idle and residual balances, and returns that are due, are flagged automatically — with an evidenced trail of what was returned, when and to whom. |
| Rule 5 | Withdraw from client account only for a proper purpose and on proper authority. | Payments run through multi-step approval with segregation of duties and limits; every withdrawal is authorised, reconciled and recorded. |
| Rule 6 | Correct breaches promptly; replace shortfalls on client account. | Same-day detection of shortfalls and excesses, with the required top-up calculated and remediation tracked to completion. |
| Rule 8.3 | Three-way reconciliation of client account at least every five weeks, signed off by the COFA. | Continuous, automated three-way reconciliation — not every five weeks — with COFA review and sign-off captured on the record. |
| Rules 8.1 & 13 | Keep accurate, contemporaneous records and retain them for the required period. | An immutable, timestamped record of every movement and calculation, retained and instantly retrievable. |
| Rule 12 | Obtain an accountant’s report and deliver it to the SRA where required. | One source of truth makes the annual accounts examination faster and cleaner, with machine-readable exports for your reporting accountant. |
Managers must segregate, calculate and continuously reconcile client money placed on deposit or with counterparties, and evidence ownership of holdings. Weak trust-status documentation and periodic reconciliation are exactly what the FCA has penalised.
Aberdeen Asset Managers was fined £7.2m by the FCA after client money placed in money-market deposits was not properly protected with trust-status documentation.
Source: FCA / BBC, September 2013.
Administration lives or dies on reconciliation and record-keeping. When those controls are periodic or manual, mismatches surface late — and are slow and costly to unpick.
The modern client-asset regime was shaped by the 2008 failure of Lehman Brothers, where separating client money and assets from the firm’s own took years and billions in cost.
Source: FCA Client Assets regime background.
Safekeeping and client money both demand entity-specific reconciliation and accurate ownership records. The FCA’s largest client-asset penalties have turned on exactly these controls.
BNY Mellon was fined £126m by the FCA for CASS failings, including not conducting entity-specific external reconciliations or keeping adequate records.
Source: FCA, April 2015.
Client money and assets must be segregated from the firm’s own and reconciled continuously. The largest client-asset fine on record turned on segregation failures.
Barclays was fined a then-record £37.7m after £16.5bn of client custody assets were not properly segregated from the firm’s own.
Source: FCA / BBC, September 2014.
Holding client money and assets brings CASS obligations that periodic, manual processes struggle to meet — including timely internal reconciliations and accurate records.
Charles Schwab UK was fined £8.96m for failing to adequately protect client assets, including not completing compliant internal reconciliations.
Source: FCA, December 2020.
Administering client cash and assets across structures and jurisdictions — including Jersey and Guernsey — means controls and records that stand up to regulators on every side.
The Jersey regulator imposed a civil financial penalty of £803,661 on a trust and corporate services provider for control and compliance failings.
Source: Jersey Financial Services Commission, 2022.
Safeguarding depends on daily reconciliation and accurate records of customer funds. When those slip, shortfalls build unseen — and customers bear the loss if a firm fails.
The FCA found that payment firms which became insolvent between 2018 and 2023 had, on average, a 65% shortfall in the funds owed to their customers.
Source: FCA safeguarding proposals, 2025.
Firms holding client money under the ICAEW Clients’ Money Regulations must keep it separate, reconciled and within permitted limits — and breaches draw disciplinary action.
An ICAEW member was fined £15,000 plus costs over unauthorised withdrawals of client money; the ICAEW continues to sanction Clients’ Money Regulations breaches.
Source: ICAEW disciplinary orders, 2022.
Register accuracy and clean distribution reconciliation are everything — unreconciled corporate actions and stale records leave rightful owners unpaid and money unaccounted for.
The client-asset regime exists because reconstructing who owns what after the fact is slow and costly; accurate, contemporaneous records are the regulator’s baseline expectation.
Source: FCA CASS record-keeping requirements.
See Saafehouse run your client money controls.
Book a demo