Within this paper, we identify some areas where we consider that the FCA has scope to change or to add to its existing guidance in ways that would be of benefit to the industry without compromising customer protection and other areas where legislative change would be of value.

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Payment Services: Making Safeguarding Work

The FCA has published detailed guidance as to how safeguarding is to work but many institutions find difficulties in complying with this guidance and particularly requirements that:

  • Relevant funds received into a safeguarding account must not be mixed with other funds so that at all times one needs to be capable of identifying and quantifying relevant funds;

  • ‘Payment and e-money institutions are expected to match the value of payments they make on behalf of their clients from their own funds because they will have to both keep the value in a safeguarding account and remit it to the payee’.

Who we help

We are specialists in providing regulatory advisory services to a broad range of financial services institutions including payment services and e-money, challenger banks, cryptocurrency, and investment firms.


How we help

We work across three core areas of regulatory compliance, financial crime and cyber security and provide a range of services including compliance advice, authorisations, audits, interim roles and compliance training.

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At fscom, we strive to offer excellent service in a professional and personable manner. We deliver this through our unrivalled understanding of financial services regulation and a strong emphasis on taking a commercial and innovative approach that puts our clients’ needs first.

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