Client Asset Protection: What the Regulations Actually Require (And What They Don't Say)
The collapse of FTX vaporised $8.7 billion in customer deposits because client assets were never actually protected. MiCA and UK CASS now establish detailed requirements for segregation, reconciliation, consent, and governance. For compliance teams, the work isn't reading the regulations. It's reading them as risk documents: identifying where definitions have expanded, where operational models trigger obligations they weren't designed for, and where the gap between stated compliance and actual protection might surprise you in insolvency.
