Focused comparison
Australia custody/client assets vs United Kingdom custody/client assets
A focused comparison for custody/client assets businesses choosing between Australia and United Kingdom.
| Question | Australia | United Kingdom |
|---|---|---|
| Likely route | AFSL custody, depository, client money, and responsible entity analysis | FCA safeguarding, custody, CASS, arranging custody, and prudential analysis |
| Key people | Responsible managers with appropriate competence and organisational capacity Authorised representatives where services are provided under another licensee | Senior Manager Function approval where a controlled function applies Certification for relevant staff under SM&CR where applicable |
| Corporate evidence | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers |
| Capital/resources | Financial resource expectations depend on authorisations, financial products, client money/custody, and licensee obligations. | Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model. |
| Timeline | Often 4 to 8+ months depending on authorisations and proof quality. | FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months. |
| Common bottlenecks | Requested authorisations are broader than the actual operating plan can support Responsible manager evidence is thin or not matched to all authorisations | Permissions requested do not match the actual operating model Financial forecasts are inconsistent with the applicant legal entity or prudential category |