CASS: offshoring and the firm's responsibilities

It is increasingly common (particularly among matched principle CFD brokers) that certain key CASS functions (such as completion of reconciliations) are completed by employees of a group outside of the UK (so called ‘offshoring’).

The responsibilities of the firm in these instances remain the same as if the function is not outsourced. It is the firm's responsibility to maintain proper oversight of any functions undertaken by teams outside of the UK (and these should be treated as part of the firm).

This would include (but is not limited to):
  • ensuring that the CF10a (or for a CASS small firm, the individual responsible for CASS oversight) properly reviews the processes undertaken by the offshore team;
  • the designing of any processes, policies or procedures is properly undertaken by the firm and that proper training is given to the offshore team on these processes;
  • the firm ensures the overseas team is provided with sufficient and appropriate training on the FCA and CASS rules and that this is properly documented and evidenced.

We have seen instances of functions being ‘offshored’ where the firm does not always appear to have full oversight of what the offshore teams are doing, and where there is any oversight this is often not fully documented or regularly monitored. This is currently an area of focus for the FCA and so should be something firms are prioritising. This should also be considered as firms develop their plans for the introduction of the Senior Manager Regime next year .

How we can help
Our CASS specialists are able to assist you with your obligations, whether that’s helping to design appropriate procedures and monitoring programmes or undertaking CASS health checks.

If you would like to discuss how the issues raised in this article affect your business please contact one of the team.

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