Partner Chris Roberts has provided comment in ICLG News and Law360 on asset servicing bank, CACEIS UK, agreeing to pay £31.7 million to WealthTek investors over serious failings in its anti-money laundering and client due diligence controls between October 2020 and April 2023.

Noting the takeaways for companies, Chris commented: “This FCA decision highlights that firms cannot rely on compliance work carried out by others, even in the context of a merger. Each firm remains responsible for conducting its own due diligence and taking appropriate action in response to any issues identified.”
 
Commenting on CACEIS UK’s serious failings, Chris said: “During the merger of CACEIS and KAS, CACEIS noted restrictions on the FCA register relating to WealthTek, a KAS client, but nevertheless adopted KAS’ risk assessment of WealthTek, despite WealthTek lacking FCA permission to hold assets on the CACEIS platform.

“CACEIS also failed to act when the issue arose on at least two later occasions and did not carry out follow-up actions it had itself identified after reviewing the FCA register. Failure to follow through on its own agreed actions is always an easy issue for the FCA to identify.“These failings contributed to customers of WealthTek losing significant sums of money.”

“However, CACEIS did ultimately identify the issue, exit the client, and its cooperation would have generated a 30% discount on its fine, though it voluntarily increased its payment to be distributed amongst those who had lost money following WealthTek’s collapse.”

Addressing the issues that likely influenced CACEIS to cooperate in full, he said:  “Although it is unclear how CACEIS’ issues concerning WealthTek first came to light, the FCA’s reference to “full and significant cooperation” suggests they self-reported and that CACEIS engaged constructively throughout the investigation. If accurate, this decision was likely influenced by the wider issues surrounding WealthTek, including the fact that the FCA is currently prosecuting WealthTek’s former principal partner on charges relating to an alleged £64 million fraud and money laundering scheme.

“Additionally, CACEIS will have been mindful of the potential fine it could have faced, which, had it not been entitled to a settlement discount, would have been broadly equivalent to the amount it ultimately agreed to pay voluntarily. In adopting this approach, CACEIS enabled the FCA to deal with the matter expeditiously and focus its resources on the other issues arising from the collapse of WealthTek, principally the criminal trial scheduled for 2027, as the FCA recognised.” 

Commenting on the FCA’s wider strategy, Chris added: “More broadly, the outcome reflects the FCA’s continued use of voluntary resolution mechanisms where firms cooperate fully and remediate promptly. This allows investigations to be concluded more quickly, conserves enforcement resources, and enables greater focus on more serious or contested cases. Firms that self-report and cooperate should be able to expect this approach to remain a feature of the FCA’s enforcement strategy.”

Chris’ comments were published in ICLG News, 26 June 2026, and Law360, 1 July 2026.