Chief Financial Officer (CFO) – Safeguarding & CASS 15
Location: London, United Kingdom – Hybrid
Industry: Fintech / Payments / Electronic Money Institution (EMI)
Employment Type: Full-time, Permanent
Alternative: Interim-to-permanent may be considered for the right specialist
About the Role
We are seeking an experienced Chief Financial Officer (CFO) to join an FCA-regulated Electronic Money Institution (EMI) in London.
This is a safeguarding-led CFO position. The immediate priority is ensuring the effective safeguarding of customer funds under the FCA's CASS 15 regime and the Electronic Money Regulations 2011, including safeguarding reconciliations, audit readiness, regulatory reporting and the overall control framework.
We are specifically looking for someone who has personally owned and worked hands-on with safeguarding within an FCA-regulated EMI or Payment Institution.
General oversight of a regulated finance function will not be sufficient. The successful candidate must understand the practical "nuts and bolts" of safeguarding, including reconciliations, shortfall resolution, segregation of customer funds, safeguarding accounts and banks, audits and regulatory requirements.
Alongside this technical expertise, the CFO will lead the wider finance function and work closely with the CEO, Board, Compliance, Risk and Operations teams.
Key Responsibilities
Safeguarding & CASS 15 – Primary Focus
- Take personal senior ownership of the company's safeguarding framework, ensuring compliance with CASS 15, the Electronic Money Regulations 2011 and relevant FCA requirements.
- Oversee daily internal and external safeguarding reconciliations, including investigation of discrepancies and timely resolution of safeguarding shortfalls.
- Ensure appropriate segregation and protection of customer funds.
- Oversee designated safeguarding accounts and relationships with safeguarding banks.
- Lead and own the annual safeguarding audit and any regulatory safeguarding reviews, including preparation, auditor/FCA engagement and remediation.
- Own safeguarding regulatory reporting and records, including the relevant periodic safeguarding return and resolution pack requirements.
- Maintain and strengthen safeguarding policies, procedures, controls and governance.
- Ensure the business remains ready for evolving FCA safeguarding requirements.
- Lead, coach and challenge the finance and operations teams responsible for day-to-day safeguarding activities, establishing appropriate review and escalation processes.
Finance Leadership
- Lead financial strategy, budgeting, forecasting, planning and financial reporting.
- Oversee accurate and timely FCA regulatory returns.
- Manage regulatory capital, own funds calculations, liquidity and financial risk.
- Oversee management accounts, statutory financial statements and cash-flow forecasting.
- Lead treasury operations, banking relationships, cash management and liquidity planning.
- Work closely with Compliance and Risk to identify and manage financial, operational and safeguarding risks.
- Provide financial and regulatory insight to the CEO and Board.
- Develop and strengthen financial controls, accounting processes and governance frameworks.
- Oversee tax compliance, statutory accounting and other financial obligations.
- Build, manage and develop the finance function, ensuring strong accountability, controls and regulatory compliance.
Essential Requirements
To be considered, candidates must have:
- Direct, hands-on CASS 15 / safeguarding experience within an FCA-regulated EMI or Payment Institution, where safeguarding formed a core part of their own responsibilities.
- Personal experience running or directly overseeing safeguarding reconciliations, including internal/external reconciliations, discrepancies and shortfall resolution.
- Direct experience with the segregation and protection of customer funds, safeguarding accounts and safeguarding banking relationships.
- Experience leading or owning a safeguarding/CASS audit or regulatory safeguarding review, including direct interaction with external auditors, the FCA and/or safeguarding banks.
- Strong working knowledge of the Electronic Money Regulations 2011, Payment Services Regulations 2017 and FCA safeguarding requirements.
- Significant senior finance leadership experience, ideally as CFO, Finance Director or Head of Finance within an FCA-regulated EMI or Payment Institution.
- Experience with regulatory capital, own funds, liquidity and FCA regulatory reporting.
- Experience leading finance/operations teams and reporting at Board level.
- A recognised professional accounting qualification: ACA, ACCA, CIMA or equivalent.
Desirable Experience
- Strong treasury, financial controls, financial risk and regulatory governance experience.
- Interim or turnaround finance leadership within a regulated payments business.
- Experience strengthening or remediating safeguarding frameworks and controls.
- Strong commercial, analytical and problem-solving skills.
- Ability to operate effectively in a fast-paced, highly regulated fintech environment.
Application & Shortlisting Process
As safeguarding expertise is central to this position, applicants should ensure their CV clearly demonstrates their direct, hands-on CASS 15 / safeguarding experience.
Candidates shortlisted for the next stage will be required to provide a brief statement of no more than 200 wordscovering:
- The FCA-regulated EMI or Payment Institution where they gained their CASS 15 / safeguarding experience.
- Their role and the period during which they held the responsibility.
- What they personally owned or carried out, particularly safeguarding reconciliations, shortfall management, safeguarding accounts/banks, audits and FCA engagement.
- The most recent safeguarding audit or regulatory review they personally led or were directly responsible for, including the outcome.
The statement can be provided directly to the recruiter following shortlisting. A separate document is not required at the initial application stage.
Please note: General experience within a regulated financial services organisation, without direct hands-on CASS 15 / safeguarding experience in an FCA-regulated EMI or Payment Institution, will not meet the requirements of this position.
