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Key definition
Client definition

What does Client mean? In legal practice, a client is the person or organisation for whom a lawyer or law firm acts and to whom professional duties are owed. This includes individuals, companies, partnerships and public bodies, whether instructing directly or through an agent. The term is a general professional expression rather than a statutory definition; its scope is shaped by engagement terms (the retainer) and by professional conduct rules and case law on duties of care, conflicts of interest, confidentiality and legal professional privilege. Key features include: identifying the correct client at the outset (especially for corporate clients, where the client is the entity,...

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UK CASS 7A client money distribution and transfer: primary/secondary pooling events, SAR/IBSA interaction, CCP porting, Brexit (UK EMIR, TTP/TPR, FSCR), and Dormant Assets Act 2022 updates

Practice notes
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Application and purpose of the Client money Distribution and transfer rules

The client money distribution framework was overhauled on 1 January 2013 to meet the requirements of articles 39 and 48 of the EU European Market Infrastructure Regulation (Regulation (EU) No 648/2012, OJ L 201, 27.7.2012) (EU EMIR).

Following the UK’s departure from the EU, this legislation was kept as the retained European Market Infrastructure Regulation (UK EMIR) (see Impact of Brexit on CASS and the FCA’s powers and requirements below).

Subsequent modifications were introduced in July 2013 through policy statement PS14/9: Review of the Client assets regime for investment business, implementing consequential revisions to the client money distribution provisions prompted by the extensive range of proposed amendments to the client money rules set out in PS14/9.

Material further changes were made in July 2017 via policy statement PS17/18: CASS 7A and the special administration regime review.

For further detail on these developments, see Changes to speed up the return of client money on insolvency...

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Web page updated on 22/05/2026

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