CACEIS Bank UK Branch FCA Final Notice: WealthTek Custody AML Lessons

On 19 June 2026 the Financial Conduct Authority (FCA) issued a final notice to CACEIS Bank (UK Branch), a custodian, and announced a public censure on 25 June 2026. There was no fine in the notice, but the FCA said it would otherwise have imposed a penalty of £32,988,540, reduced to £23,091,900 by a 30% settlement discount, and the firm agreed a voluntary payment of £31,714,068 for the clients of WealthTek. WealthTek was a wealth manager that entered special administration in April 2023. For compliance teams the case is a reminder that anti-money laundering (AML) duties do not end with a handover from another firm: the custodian inherited a "low risk" rating, never revisited it, and did not act when a basic regulatory check showed that the customer had no permission to hold client money. If you are building your AML knowledge, see our CPD courses.

This guide is based on the FCA's final notice. We read it through a summarising tool, so check every figure against the notice before you quote it.

Who CACEIS UK is and what happened

CACEIS Bank (UK Branch), referred to as CACEIS UK, is the UK branch of CACEIS Bank S.A. It provides securities services, including custody, mainly to regulated UK clients. After a merger in November 2020 it took over the clients of KAS UK, including WealthTek. The relevant period in the notice is 1 October 2020 to 4 April 2023.

The FCA found that CACEIS UK breached Principle 2, which requires a firm to act with due skill, care and diligence. The notice cites the systems and controls rules in SYSC 6.1.1R, 6.3.1R and 6.3.3R and regulations 18, 27 and 28 of the Money Laundering Regulations 2017, with the Joint Money Laundering Steering Group guidance as background. Credits into WealthTek accounts exceeded £314 million during the period.

The failings in detail

A risk rating that was inherited and never reassessed

CACEIS UK adopted KAS UK's "low risk" rating for WealthTek and did not reassess it. The account was therefore placed under low vigilance and simplified due diligence. The lesson for any firm that takes on clients through a merger or transfer is that the previous firm's risk rating is an input, not a conclusion. The new firm must assess the customer against its own risk appetite.

Customer due diligence left out of date

An alert in October 2021 noted incomplete or incorrect know-your-customer information. The FCA found no evidence that the information was sufficiently updated afterwards.

Ongoing monitoring that stalled

The firm used a legacy monitoring system. Sixteen alerts were raised between October 2021 and February 2022, but only 11 full records survived. The notes on five alerts showed the firm's policy requirements had not been met. Ten of the 11 were accessed in April 2023, but no substantive action followed for 14 months. The 11 were closed as false positives in June 2024 and the last alert was closed in March 2025. Our guide to suspicious activity reporting explains why alerts that sit unreviewed can turn a monitoring system into a record of missed warnings.

Governance: the permission check that was not acted on

CACEIS UK migrated and opened accounts although Financial Services Register checks showed that WealthTek lacked the permission to safeguard client assets. The firm did not act on this in March 2021 or December 2022, and it missed a restriction barring WealthTek from holding client money. It acted only after WealthTek asked for an updated agreement in late 2022. Our guide to the Barclays UK WealthTek final notice covers the same missed Register check from the bank's side.

Why a censure and not a fine

The notice records that the breach was neither deliberate nor reckless, but that it exposed the firm and WealthTek's underlying clients to a risk of loss, and that the permissions issue took more than two years to address. CACEIS UK made no direct profit. The FCA weighed these points against the firm's cooperation, which it described as full and significant from the start of the investigation: CACEIS UK accepted the failings early, responded promptly and provided information beyond its legal obligations. It has no previous disciplinary record. We read the notice's explanation only through a summary, so please read the notice itself for the exact link between the voluntary payment and the decision to censure.

Remediation

CACEIS UK notified the FCA in February 2023 and decided to exit WealthTek, although WealthTek entered special administration in April 2023 before the exit was complete. It introduced a new AML alert-handling policy in May 2024 and has retired the legacy monitoring system. The notice does not describe broader remediation in the text we read.

Practical lessons

• Re-assess inherited customers. Do not carry over another firm's risk rating without your own review.
• Use the Register. Checking a client's permissions on the Financial Services Register is a basic control, and the check must lead to action.
• Close the loop on alerts. Alerts that are opened but not actioned for over a year are a serious finding.
• Keep records. Only 11 of 16 alerts had full records, which weakens any defence.
• Act when the facts change. The firm moved only when its client asked for a new agreement.

The same theme of weak onboarding and monitoring features in our CB Payments final notice guide.

Frequently asked questions

Was CACEIS UK fined?

No. The FCA issued a public censure. The notice says it would otherwise have fined £32,988,540, reduced to £23,091,900 by a 30% settlement discount. The firm agreed a voluntary payment of £31,714,068 for WealthTek's clients.

What rules did the FCA rely on?

Principle 2, SYSC 6.1.1R, 6.3.1R and 6.3.3R, and regulations 18, 27 and 28 of the Money Laundering Regulations 2017.

Does a custodian have AML duties?

Yes. A custodian is a regulated firm and must apply customer due diligence and ongoing monitoring to its clients.

What we could not confirm

We read the FCA's final notice through a summarising tool. The notice does not state the number of WealthTek's underlying clients or accounts, nor the number of transactions, and we did not confirm how the voluntary payment is to be distributed. Please check all figures against the notice.