Client funds segregated, reconciled daily and audited to the standard each regulator sets, with the arrangements, the accounts and the evidence in place from the first day of authorisation.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Every payment and e-money licence carries one promise: customer funds are protected. Each regulator sets its own method, whether segregation in a designated account, an insurance policy or guarantee, or a trust arrangement, and each expects daily reconciliation, clear records and an independent audit. We design the arrangement, open the accounts, write the procedures and run the reconciliation on Safeheld, the firm’s own platform.
In the United Kingdom the rules moved to a client-assets model with a dedicated sourcebook; in Europe, the United States, Canada, Australia and Singapore the requirement is set by the licence. The programme is built once and mapped to every market the firm serves.
The safeguarding method chosen for the firm’s flows, the accounts required, the acknowledgement letters and the governance over them.
Designated accounts opened with institutions that understand the requirement, with the correct naming, letters and controls.
Internal and external reconciliation every business day on Safeheld, with discrepancies escalated and resolved on record.
The safeguarding policy, the resolution pack and the records a regulator or administrator would need.
Preparation for, and management of, the annual safeguarding audit, with findings closed before the next cycle.
Monthly returns and attestations where required, and the board reporting that evidences oversight.
| Deliverable | What it contains | Who relies on it |
|---|---|---|
| Safeguarding arrangement | Method, accounts, letters, governance and the resolution pack | Regulator, auditors, administrators |
| Reconciliation records | Daily internal and external reconciliations with exception logs on Safeheld | Regulator, auditors |
| Safeguarding policy | Policy and procedures covering receipt, segregation, reconciliation and discrepancies | Staff, auditors |
| Audit file | Evidence pack for the annual audit and the management response | Auditors, board |
| Board report | Monthly oversight report with balances, exceptions and attestations | Board, regulator |
Segregation in a designated account with an authorised institution, an insurance policy or comparable guarantee, and in some jurisdictions a trust or escrow structure. The right method depends on the flows, the jurisdiction and the institutions available to the firm.
Most regimes require relevant funds to be segregated by the end of the business day following receipt; some require it on receipt. The arrangement is designed to the strictest standard that applies to the firm.
Yes. Through the firm’s banking relationships we open designated accounts with institutions that recognise the requirement, with the acknowledgement letters regulators expect.
Safeheld is the firm’s safeguarding and reconciliation platform. It reconciles daily, records exceptions, produces the regulatory returns and keeps the audit trail in one place.
In the United Kingdom and several other markets, yes. Elsewhere the regulator may require an auditor’s report on request. We prepare the firm for either.
A reply within three business hours and a written proposal on scope, cost and timing the same day.