FCA has fined Aviva Pension Trustees UK Limited and Aviva Wrap UK Limited £8,246,800 for failings in oversight of outsourced service providers for client assets. It found that Aviva had not put appropriate controls in place over its third party administrators and, as a result, had not been able properly to challenge the providers’ controls, competence and resources. Additionally, it did not have proper resource or expertise to implement effective CASS oversight or to address CASS-related problems. Finally, FCA found deficiencies in Aviva’s internal reconciliation process, which resulted, at worst, in under-segregation of nearly £75 million of client money. As a result of the failings, Aviva could not meet several CASS requirements. FCA noted there was no actual loss of money or assets, but also that the failings were particularly serious as CASS rule breaches had previously been identified to the firm.