Between January 2008 and January 2010, CIL failed to hold client money in segregated accounts with trust status. The firm also failed to implement and maintain adequate controls over its client money as required by FSA rules. In particular, for two years CIL failed to verify that certain accounts had been appropriately set up as client money accounts.

These accounts related to a number of unregulated collective investment schemes managed by CIL. CIL was responsible for ensuring that all periodic distributions were paid directly to investors.

In January 2008, a new process was put in place by the administrator of the funds and the process for distributions was outsourced. To facilitate the new process CIL arranged for distribution accounts to be opened in relation to each fund in order to pay distributions to investors.

These accounts should have been set up as segregated client money accounts with trust status but CIL failed to do this. It also failed to pick up that the accounts did not have the required trust status.

Margaret Cole, FSA director of enforcement and financial crime division, said:

"Customers should be able to assume that authorised firms have the right systems and controls to safeguard their assets. CIL put clients at risk of significant financial loss by failing to segregate client money appropriately for a period of two years" this is simply unacceptable.

"It is essential for firms to adhere to our client money rules and recent action in this area shows that our focus has intensified. Firms should be in no doubt that if they fail to get their house in order in this regard we will take action against them."

CIL proactively notified the FSA after identifying the problem and co-operated with the FSA in the course of its investigation. CIL agreed to settle at an early stage and so qualified for a 30% discount. Without the discount the fine would have been £140,000.

The FSA has established a new unit to enhance and strengthen the FSA's existing capabilities in the area of client money and assets. The unit consists of teams responsible for specialist supervision, policy, data analysis and risk management.