Beyond the baseline

How BCB strives to exceed minimum standards for safeguarding client funds

In an era of heightened regulatory scrutiny and evolving financial infrastructure, safeguarding client assets has become more than a compliance exercise, it’s the cornerstone of institutional trust. At BCB Group, we are committed to going beyond the minimum standards and building systems that endure. That is why we are currently in the process of implementing new safeguarding procedures to ensure our clients’ assets are protected from the latest emerging threats. 

The Financial Conduct Authority (FCA) has acknowledged that its existing safeguarding guidance, introduced as a stopgap post-Brexit, lacks the robustness required for today’s rapidly evolving financial landscape. In response, the regulator is transitioning to the CASS (Client Assets Sourcebook) regime, a framework informed by lessons from post-Lehman insolvencies. 

For Chizoba Uzowuru, Director of Safeguarding at BCB, this shift is both welcome and overdue.

Coming from a background where CASS was the standard, she explains that this regime is “tried and tested.”

“It provides clarity and structure in a way that previous guidance did not. It’s more rule-based now, which helps firms like ours protect client money with greater precision.”

BCB has not waited for the final rules before deciding to act. As soon as the consultation was published, it began conducting a thematic review of its safeguarding policies and procedures to identify opportunities for uplift and improvement. It hopes this proactive stance will position it ahead of its competitors, with many of the expected requirements either already embedded or expected to be embedded in its operations once the implementation period is complete. This is a complex, delicate process that takes many months, which is why it’s important to be proactive where possible.

“We’re getting ahead of the changes now,” says Uzowuru. “We’ve engaged with our third-party reconciliation provider to enhance record-keeping and reporting. That way, when the policy is finalised, we can integrate the additional requirements seamlessly.” BCB’s safeguarding function is now involved at the earliest stages of product development and jurisdictional planning, rather than retrofitting controls after launch.

“We’ve shifted our mindset,” Uzowuru notes. “Safeguarding is no longer an afterthought. It’s part of how we build, how we assess jurisdictions, and how we protect client money across our global network.”

BCB is currently in the process of extending its cross-functional integration to technology, product and operations teams. Roadmaps should include ledger enhancements, reporting upgrades and deeper due diligence with partner banks.

“We’re proactively asking our banking partners for evidence to support their alignment with our safeguarding standards,” she says. “We’ve already tested one of our major US. banks, and the results have strengthened our overall review.”

While BCB is well-positioned, Uzowuru acknowledges that the transition will be challenging for many firms in the payments and e-money space. Unlike banks, which underwent similar reforms a decade ago, smaller institutions may lack the capital and infrastructure to adapt quickly.

“The feedback across the industry is mixed,” she says, “but it’s a heavy lift for firms without the resources we have. That’s why we’ve advocated for a longer implementation period, nine months instead of six, to give everyone a fair chance to comply.”

The FCA originally gave firms six months to prepare for these rules; however, it extended this period to nine months. As part of the consultation, BCB submitted feedback and potential recommendations to the FCA, highlighting areas where the proposed rules could benefit from greater precision. One example is the definition of a “business day”, a term that may not reflect the 24/7 nature of fintech operations.

Another concern is the potential divergence between UK and EU standards. With BCB operating across both regions, maintaining competitiveness and consistency is key.

“The FCA wants to promote innovation and support UK businesses,” she says. “But they also need to ensure the rules don’t push firms to relocate to jurisdictions with more flexible frameworks.”

Looking ahead, BCB is closely monitoring emerging CASS rules for crypto and stablecoin custody. While its model aligns more closely with Europe’s MiCA regulation, the firm remains engaged in UK consultations and committed to shaping the future of digital asset safeguarding.

“The fact that regulators are looking at crypto and stablecoins shows they’re serious about maturing this industry,” Uzowuru says. “We’re part of that conversation.”

To support transparency, BCB is also considering publishing a guide to its safeguarding framework, helping institutional clients better understand the firm’s approach and reassure them of its commitment to asset protection.

“We already share this information with clients,” she adds. “Publishing information about our framework would make it easier for them to access and align with our approach.”