Training Objectives

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

• Interpret the core safeguarding obligations under MiFID II, Law 87(I)/2017 and CySEC Directive DI87-01.
• Design and maintain appropriate bank account structures for client money and own funds.
• Perform accurate daily and monthly client-money reconciliations in line with CySEC expectations for onsite and offsite inspections.
• Establish clear procedures for identifying, monitoring and documenting unclaimed and dormant client assets.
• Prepare evidence packs, registers and reconciliation files that can be readily provided to CySEC or external auditors.
• Identify and remediate typical gaps and weaknesses discovered during inspections and internal audits.

Training Outline

Regulatory Framework & Safeguarding Obligations

• MiFID II safeguarding principles and investor protection rationale
• Key provisions of Law 87(I)/2017 related to client funds and assets
• CySEC Directive DI87-01: core safeguarding requirements and practical interpretation
• What CySEC expects to see in policies, procedures, and organisational arrangements

Designing and Maintaining Bank Account Structures

• Segregation of client funds vs own funds in practice
• Structuring client bank accounts (pooled, omnibus, segregated) and related risks
• Bank selection, diversification and monitoring of credit/concentration risk
• Ongoing maintenance: opening/closing accounts, signatory control, and governance oversight

Client Money Reconciliations: Methodology, Templates & Demonstration

• Types of reconciliations (internal vs external; daily vs monthly) and when each applies
• Defining reconciliation methodology, data sources and cut-off times
• Live walk-through: performing accurate daily and monthly reconciliations as per CySEC expectations
• Handling breaks, investigating differences, escalation and approval workflow
• Documenting and storing reconciliation files to withstand onsite and offsite inspections

Unclaimed, Dormant and Residual Client Assets

• Definitions and regulatory expectations for unclaimed and dormant assets
• Procedures for identifying, monitoring and tagging dormant/unclaimed balances
• Communication with clients, reminders, and escalation paths
• Accounting, legal and tax considerations; residual balances and write-off policies
• Maintaining registers and audit trails for CySEC and external auditors

Evidence Packs, Registers and Inspection Readiness

• Building complete evidence packs: reconciliations, registers, approvals, and control logs
• Structuring safeguarding and unclaimed-assets files for easy provision to CySEC or auditors
• Examples of effective documentation vs weak/insufficient evidence
• Checklists for pre-inspection self-assessment (onsite and offsite)

Common Gaps, Weaknesses & Remediation Approaches

• Typical deficiencies found in Cyprus Investment Firms during inspections and audits
• Root cause analysis: process design, staffing, systems and governance failures
• Designing and prioritising remediation action plans
• Monitoring implementation and evidencing closure of findings
• Open Q&A – addressing firm-specific safeguarding and unclaimed assets challenges (no-name basis)

Who Should Attend

This programme is designed for:

• Compliance Officers and Compliance Assistants
• Risk Managers and Operational Risk Officers
• Finance Managers, Accountants and Back-Office / Reconciliation staff
• Heads of Operations and Middle-Office staff
• Internal Auditors
• Executive Directors, Non-Executive Directors and Senior Management of Cyprus Investment Firms who need clear assurance that client funds and unclaimed assets are managed in full compliance with CySEC expectations.
• Members of ICPAC acting as external auditors for CIFs

Training Style

The programme is highly practical, interactive and case-study-driven. The trainer uses real-life examples, live reconciliation demonstrations and structured templates, encouraging participant questions throughout.

The focus is on turning regulatory text into concrete checklists, workflows and documentation that can be implemented immediately.

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.