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Practical Compliance: Safeguarding Client Funds & Managing Unclaimed Assets

Practical Compliance: Safeguarding Client Funds & Managing Unclaimed Assets

Dates

  • October 2026
      to   (2 sessions)
    Delivered Online
    €240+ VAT
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Highlights

  • Live Online

  • 5 CPD Units | 5 Hours


The EIMF Live Online Learning Experience

Participants will receive access to the recorded sessions of the course.

EIMF subject-matter experts deliver engaging and interactive courses across a broad spectrum of areas, that can be enjoyed in the comfort of your own chosen environment. Read more


Course Overview

This practical programme addresses the safeguarding lifecycle for client money, financial instruments, uninvested funds and dormant or unclaimed balances in Cyprus Investment Firms. It is aligned with MiFID II, Commission Delegated Directive (EU) 2017/593, Law 87(I)/2017, as amended, CySEC Directive DI87-01, and relevant CySEC safeguarding and uninvested funds supervisory expectations. The seminar translates legal obligations into daily operating controls: account structuring, segregation, bank and custodian due diligence, daily and monthly reconciliations, break investigation, treatment of interest or returns on uninvested funds, dormant-client identification, client communication and inspection-ready documentation.

It also covers DORA, in which reconciliation systems, bank connectivity, data integrity, outsourced providers, and incident response affect the safeguarding environment. Participants leave with a structured evidence pack model that can be used for CySEC requests, external audit, Internal Audit and Board assurance.


Training Objectives

By the end of the programmer, participants will be able to:

  • Interpret the core safeguarding obligations under MiFID II, Delegated Directive (EU) 2017/593, Law 87(I)/2017 and CySEC Directive DI87-01.

  • Design bank, custodian and omnibus/segregated account structures that protect client assets and evidence proper separation from own funds.

  • Perform and document daily, monthly, internal and external reconciliations using clear data sources, cut-off times and escalation logic.

  • Identify, investigate and remediate reconciliation breaks, residual balances, suspense items and unexplained differences.

  • Develop procedures for uninvested funds, interest/returns, dormant balances, unclaimed assets and client communication cycles.

  • Assess bank/custodian concentration risk, due diligence, agreements, acknowledgements and ongoing monitoring.

  • Integrate DORA-driven resilience into safeguarding systems, reconciliation tools, backup data, outsourcing and business continuity testing.

  • Prepare evidence packs, registers, MI and board reporting capable of withstanding CySEC onsite/offsite inspections and external audit challenge.


Training Outline

Regulatory Framework and Safeguarding Perimeter

  • MiFID II and Law 87(I)/2017 principles: client asset protection, organisational arrangements and investor protection.

  • Commission Delegated Directive (EU) 2017/593 and CySEC Directive DI87-01: safeguarding, product governance and inducements connection.

  • Client money vs financial instruments vs uninvested funds vs dormant/unclaimed balances.

  • Roles of Finance, Operations, Compliance, Risk, Internal Audit and the Board.

Account Structuring, Bank/Custodian Selection and Segregation

  • Client bank account naming, account purpose, own funds separation and pooled/omnibus structures.

  • Bank/custodian due diligence, diversification, credit and concentration risk.

  • Acknowledgement letters, authorised signatories, payment controls and change management.

  • Evidence expected in client-asset policies, procedures and operational registers.

Reconciliations and Break Management

  • Daily and monthly reconciliation methodology, templates, data sources and cut-off controls.

  • Internal vs external reconciliations and matching logic.

  • Breaks: root-cause analysis, thresholds, escalation, client impact and remediation.

  • Live practical demonstration: building a CySEC-ready reconciliation file.

Uninvested Funds, Dormant Balances and Unclaimed Assets

  • CySEC thematic focus on uninvested funds held by CIFs and treatment of interest/returns.

  • Dormancy triggers, client contact cycles, returned payments and inactive accounts.

  • Residual balances, write-offs, legal review, tax/accounting considerations and client-money status.

  • Registers, audit trails and documentation required for supervisory and external audit review.

DORA, Outsourcing and Inspection Readiness

  • DORA relevance to reconciliation systems, bank connectivity, data integrity, outsourcing and incident recovery.

  • Business continuity and ICT incident playbooks for safeguarding critical processes.

  • Building a safeguarding evidence pack: reconciliations, approvals, registers, policies, MI and Board minutes.

  • Common deficiencies and remediation roadmap: design, operating evidence, independent challenge and closure validation.


Who Should Attend

This programme is designed for:

  • Chief Executive Officers, Chief Financial Officers, Chief Operating Officers, Chief Risk Officers and other C-level officers of Cyprus Investment Firms.

  • Executive Directors and Non-Executive Directors overseeing client-asset protection, finance, operations or risk.

  • Heads of Finance, Finance Managers, Accountants and Reconciliation Officers within Cyprus Investment Firms.

  • Heads of Operations, Back-Office Managers, Middle-Office Officers and Payments Officers within Cyprus Investment Firms.

  • Heads of Compliance, Compliance Officers, Risk Managers and Operational Risk Officers.

  • Internal Auditors and Internal Audit Managers reviewing safeguarding, reconciliations, uninvested funds or client-asset controls.


Training Style

The programme is highly practical and includes short technical explanations, instructional videos, live reconciliation demonstrations, Cyprus case studies, sample registers and break-management exercises. Participants work through a model evidence pack and learn how to translate regulatory text into repeatable daily controls, audit trails and Board-ready MI.


CPD Recognition

This programme may be approved for up to 5 CPD units in Financial Regulation. Eligibility criteria and CPD Units are verified directly by your association, regulator or other bodies which you hold membership.


In-house Training

For groups within the same organisation, this course may be customized to meet any specific needs and delivered in-house.

Facilitators

  • Panagiotis Nikolaou

    Panagiotis Nikolaou

    GRC Expert and Auditor

    Panagiotis Nikolaou is an accomplished Governance, Risk and Compliance Lead Auditor, strategic advisor, regulatory investigator, approved internal auditor, technical expert, ISQM 1 implementation specialist, and vocational trainer with more than 15 years of experience in the international financial services sector. His professional background encompasses financial technology (FinTech), investment services, financial markets, internal audit, regulatory compliance, risk management, market surveillance, financial crime prevention, quality management, and executive leadership within regulated financial institutions and professional services firms. Since 2018, he has served, during various periods, as a selected Associate Expert in Market Surveillance and Investigations for the Cyprus Securities and Exchange Commission (CySEC) through public tenders awarded to MAP S.Platis Group. In this capacity, he has contributed to complex regulatory investigations, on-site and off-site inspections, compliance assessments, market-conduct reviews, and evaluations of business relationships involving Cyprus Investment Firms, financial institutions, Payment Institutions, Electronic Money Institutions, and other regulated or higher-risk entities. Panagiotis has developed substantial experience in the payments and electronic money sectors, advising and auditing Payment Institutions (PIs) and Electronic Money Institutions (EMIs) in relation to governance, safeguarding of client funds, AML/CTF controls, risk management, outsourcing, operational resilience, regulatory reporting, internal control arrangements, and compliance with the supervisory expectations of the Central Bank of Cyprus. He has been approved by the Central Bank of Cyprus to act as an Internal Auditor for regulated Electronic Money Institutions and Payment Institutions, demonstrating his ability to independently assess governance, regulatory compliance, safeguarding, financial crime, operational, outsourcing, information and communication technology, and risk-management frameworks within Central Bank-supervised entities. In addition, Panagiotis has served as an ISQM 1 standards implementer and advisor for various accounting and audit firms, supporting the design, documentation, implementation, and continuous improvement of their quality management systems. His work includes conducting firm-wide quality risk assessments; identifying quality objectives, risks, and appropriate responses; developing policies and procedures; defining governance and leadership responsibilities; strengthening ethical and independence controls; establishing client acceptance and continuance procedures; enhancing engagement performance and review arrangements; and developing monitoring, remediation, documentation, and annual evaluation processes. He assists accounting and audit firms in translating the principles of the International Standard on Quality Management 1 (ISQM 1) into practical, proportionate, and sustainable control frameworks suited to their size, structure, client portfolio, and regulatory obligations. His experience is further strengthened by previous appointments as Executive Director, Risk Manager, Head of Portfolio Management, broker, technical analyst, and senior dealer within the investment services industry. This combination of supervisory, investigative, audit, advisory, executive, and frontline financial-market experience enables him to assess regulated institutions and professional services firms from both regulatory and operational perspectives. His principal areas of expertise include AML/CTF and sanctions compliance, financial crime and fraud risk, MiFID II and MiFIR, payment services and electronic money regulation, product governance, suitability and appropriateness, best execution, investor protection, safeguarding of client funds and financial instruments, complaint handling, conflicts of interest, financial promotions, internal governance, regulatory remediation, outsourcing, quality management, and operational resilience. He has also developed significant expertise in emerging regulatory areas, including crypto-assets, blockchain-based financial services, virtual-asset risk management, and the Markets in Crypto-Assets Regulation (MiCA). His international advisory work has extended to regulated entities and public authorities in the European Union, Cyprus, Israel, Russia, South Africa, Singapore, Thailand, Seychelles, Vanuatu and other jurisdictions. Panagiotis has also participated as a technical expert in legal proceedings and disputes concerning the investment services sector. His work has included the independent assessment of trading practices, order execution, pricing, best-execution obligations, financial instruments, brokerage operations, liquidity-provider arrangements, transaction costs, rollover and financing charges, and the application of the relevant European and Cyprus regulatory frameworks. Through these engagements, he assists legal professionals, courts, regulated entities, and other stakeholders in understanding complex financial market practices, trading data, and regulatory requirements by presenting technically grounded findings in a clear, evidence-based manner. As a Level 5 Vocational Trainer certified by the Human Resource Development Authority of Cyprus, Panagiotis has designed and delivered specialised professional training to a broad international audience across the financial services, regulatory, law enforcement, and professional services sectors. His training experience includes programmes delivered to personnel from some of the world’s largest internationally operating investment firms, banking institutions, Payment Institutions, Electronic Money Institutions, accounting and audit firms, and other regulated financial organisations. He has also delivered specialised training to the Cyprus Police Academy, as well as to professionals and representatives from Cyprus’s supervisory authorities, regulatory institutions, and self-regulatory and professional bodies. His audiences have included regulators, investigators, compliance officers, internal auditors, risk managers, senior executives, board members, legal professionals, and other specialists responsible for governance, financial crime prevention, investor protection, and regulatory compliance. His programmes combine detailed regulatory analysis with practical case studies, investigative methodologies, risk-based assessments, control-testing procedures, and guidance on operational implementation. The subject matter covered includes AML/CTF, sanctions compliance, bribery and corruption, fraud prevention, MiFID II and MiFIR, product governance, suitability and appropriateness, best execution, safeguarding of client assets, complaints handling, vulnerable-client protection, market conduct, payment services, electronic money, crypto-assets, MiCA, internal audit, corporate governance, and operational resilience. Through these engagements, Panagiotis has developed the ability to adapt complex regulatory and technical content to audiences ranging from supervisory and law-enforcement personnel to board members, senior management, compliance professionals, and operational teams within major international financial institutions. He has also co-authored a professional guide concerning ESMA’s knowledge and competence assessment guidelines in collaboration with the European Institute of Management and Finance and the Chartered Institute for Securities & Investment. Panagiotis holds a Bachelor’s degree in Economics, an MSc in Financial Services, and an MBA, and is currently pursuing a Doctorate in Business Administration in Strategic Management at the University of Limassol. His professional qualifications include the CySEC Advanced and AML certifications, the Certified Governance, Risk and Compliance Auditor designation, ISO 31000 Risk Management Lead Auditor, ISO 9001, ISO/IEC 27001 and ISO 45001 Lead Auditor qualifications, GDPR Lead Auditor and specialised studies in criminology, forensic science, fraud investigation, and identity-theft prevention. He is also a Chartered Member of the Chartered Institute for Securities & Investment and a full member of the Society of Technical Analysts. He is also a member of academic societies such as the Academy of Management, IFERA and others. Combining regulatory insight, investigative discipline, internal audit and quality-management expertise, legal-case support, industry experience, and strategic leadership, Panagiotis assists investment firms, financial institutions, PIs, EMIs, accounting and audit firms, supervisory stakeholders, and professional advisers in strengthening governance arrangements, enhancing regulatory compliance, implementing ISQM 1 systems of quality management, safeguarding client assets, managing financial and operational risks, and establishing practical, proportionate, and sustainable control frameworks.

Frequently Asked Questions

  • When will I receive my invoice?

    The invoice is issued on the day the course starts.

  • What payment methods are accepted?

    Payments can be made by bank transfer, cheque, or credit card.

  • When will my certificate be issued?

    Certificates are issued within 7–10 days after the course has been completed, provided that the invoice has been paid.

  • How can I access my certificate?

    Once your certificate has been issued, you will receive an automated email from Cademy notifying you that it is available.

    Click the Get Your Certificate button in the email to download your certificate.

    You can also access it from your Cademy account:

    1. Log in to your Cademy account from https://cademy.io
    2. Click on My Account from the top-right corner.
    3. From the drop-down menu select My Courses and Bookings.
    4. Choose the relevant course.
    5. Under Participants, click the three dots located next to your name. 
    6. Select Get Certificate.
  • Where can I access the course material?

    To access the course materials, such as presentations and recordings:

    1. Log in to your Cademy account from https://cademy.io
    2. Click on My Account from the top-right corner.
    3. From the drop-down menu select My Courses and Bookings.
    4. Choose the relevant course.
    5. Under Extra Details, you will find all the available course materials.

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