Safeguarding · 21 June 2025
Big changes to safeguarding: what CP24/20 means for UK payment firms
The practical impact of tighter reconciliation, audit, segregation and wind-down expectations.
More than a policy update
A CASS-style approach makes safeguarding more documented, testable and operationally demanding. Firms need clear ownership, reliable daily controls and evidence that arrangements would hold up under stress.
Immediate actions
- Review reconciliation and account-segregation processes.
- Confirm senior oversight and escalation responsibilities.
- Assess documentation and evidence against audit expectations.
- Test outsourcing oversight and wind-down readiness.