Sapia Pays £19.6m to WealthTek Clients After FCA Censure for Client Money Failings
Summary
Sapia Partners LLP has agreed to make a voluntary payment of £19,637,950 to WealthTek clients following an FCA investigation that found the firm failed to implement adequate safeguards for client money. The FCA censured Sapia for not properly separating key roles within its business, where individuals who could make payments from client money accounts also carried out the required account checks. The FCA decided not to impose a financial penalty due to Sapia's exemplary cooperation and acceptance of responsibility, with the payment to be distributed to WealthTek clients who have suffered a shortfall. The FCA investigation concluded in 12 months, which the regulator cited as evidence of improving enforcement pace.
“Sapia has agreed to make a voluntary payment of £19,637,950 to WealthTek clients and the FCA has censured the firm.”
Firms with appointed representative arrangements should review their CASS 7 client money controls, specifically ensuring that the function of making payments from client money accounts is organisationally segregated from the reconciliation/checking function. The FCA's explicit citation of Principle 10 and CASS as the applicable framework means these are the standards against which similar client money failures will be measured.
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What changed
The FCA issued a censure against Sapia Partners LLP for failures in protecting client money received from its appointed representative WealthTek LLP. The specific violation involved inadequate segregation of duties: individuals authorised to make payments from client money accounts were also responsible for conducting the required reconciliation checks, creating unacceptable risk of misuse or poor management. As a result of Sapia's voluntary cooperation and agreement to make the £19.6m restitution payment, the FCA forwent a financial penalty that would have totalled £7,412,000 after the 30% settlement discount. \n\nFirms that operate appointed representative structures and hold client money should review their CASS 7 compliance arrangements, specifically the segregation of payment authorisation and reconciliation functions. The FCA's decision to reduce penalty exposure based on cooperation may encourage firms to self-report and remediate swiftly, while the censure itself serves as a reminder that client money protection obligations extend fully to activities conducted through appointed representatives.
Archived snapshot
Apr 24, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Sapia agrees to pay more than £19m to WealthTek clients after failing to protect client money
Press Releases First published:
23/04/2026
Last updated: 23/04/2026
Sapia has agreed to make a voluntary payment of £19,637,950 to WealthTek clients and the FCA has censured the firm.
Sapia began working with WealthTek in 2013 and later appointed it as one of its appointed representatives. This resulted in Sapia holding and being responsible for protecting client money resulting from WealthTek’s activities.
The FCA found Sapia did not put enough safeguards in place to protect this money.
Sapia has admitted that it failed to properly separate key roles within its business relating to client money. People who could make payments from client money accounts also carried out the checks of those accounts required by FCA rules. This lack of separation increased the risk that client money could be lost because of, for example, misuse or poor management.
The voluntary payment will be distributed to WealthTek clients who have a shortfall in the money they have been able to reclaim.
In December 2024, the FCA, separately, charged WealthTek’s principal partner with multiple criminal offences, including money laundering and fraud.
Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said:
'Poor safeguards around client money create opportunities that bad actors can exploit. Sapia’s failures exposed clients to an unacceptable risk of losing their money.
'We decided not to impose a fine on Sapia because of its exemplary cooperation and its acceptance that it should make a voluntary payment to affected customers.'
The FCA concluded its investigation in 12 months. This is an example of how we are improving the pace of our investigations.
Notes to editors
- Final Notice 2026: Sapia Partners LLP (PDF).
- From incorporation on 24 May 2010 and until 13 January 2021, WealthTek LLP was called Vertus Asset Management LLP.
- WealthTek LLP was an appointed representative of Sapia from 2017 until becoming directly authorised by the FCA from 28 January 2020 until 4 April 2023 when the FCA took action to order the firm to cease operations and to appoint Special Administrators. Clients can see updates from WealthTek’s administrators.
- Were it not for Sapia’s agreement to make the voluntary payment of £19.6m (with the assistance of its ultimate parent company), to be distributed to WealthTek’s clients with a shortfall in the money they have been able to reclaim, and Sapia’s cooperation throughout the investigation, the FCA would have imposed on Sapia a penalty of £7,412,000 (after the 30% discount for agreeing to settle the matter).
- Of the £19.6m, WealthTek’s administrators will receive £19.1m and the Financial Services Compensation Scheme (FSCS) will receive £500,000 (in accordance with its statutory duties to pursue recoveries where reasonably possible and cost effective). Once FSCS has concluded any further recoveries actions, it will proceed to make distributions of any surplus to WealthTek’s FSCS eligible clients under the rules set out in the Compensation Sourcebook of the FCA’s Handbook.
- A trial has been scheduled for September 2027 at Southwark Crown Court in the criminal proceedings brought by the FCA against John Dance, the former WealthTek LLP principal partner.
- The FCA fined Barclays Bank UK PLC £3,093,600 for poor handling of financial crime risks in relation to a client money account opened by WealthTek. Barclays also agreed to make a voluntary payment of £6.3m for distribution to WealthTek’s clients who have a shortfall in the money they have been able to reclaim.
- Firms need to comply with Principle 10 of the FCA’s Principles for Businesses and follow the client money rules in FCA’s Client Assets Sourcebook (CASS) to ensure they arrange adequate protection for client money. This applies to client money received from a firm’s own activities or from those of its appointed representatives.
- Find out more information about the FCA.
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