Agents, Distributors & Payment Facilitator Oversight
Independent Oversight for Principals
If you are an Authorised Payment Institution (API) or Authorised E-Money Institution (AEMI) using:
- Agents
- Distributors
- Payment Facilitators
- Programme Managers
- BIN-sponsored partners
You remain fully responsible for their conduct.
Regulatory permissions cannot be delegated. Risk cannot be outsourced. Oversight must be demonstrable.
Payment Practice supports principals in designing and executing robust, proportionate oversight frameworks aligned to FCA expectations.
Your Regulatory Position
Under the expectations of the Financial Conduct Authority and the relevant provisions of the Payment Services Regulations 2017 and Electronic Money Regulations 2011, principals must:
- Monitor agents and distributors on an ongoing basis
- Ensure adequate AML and financial crime controls
- Maintain effective safeguarding oversight
- Monitor conduct of business compliance
- Ensure outsourcing and operational resilience standards are met
- Maintain adequate reporting and governance structures
In practice, the FCA increasingly asks:
How do you evidence effective oversight of your agents or Payment Facilitators?
Board assertions are no longer sufficient. Structured monitoring, documented review, and risk-based escalation are expected.
Our Services
1. Agent & Distributor Independent Review
We perform structured, risk-based reviews of agents and distributors covering:
- Governance and reporting lines
- Financial crime framework (FWRA, CDD, EDD, sanctions, PEP screening, SARs)
- Safeguarding flows and reconciliation oversight
- Complaints handling and conduct risk
- Outsourcing controls
- Operational resilience
- Consumer duty considerations
- Financial monitoring and exposure
Deliverables include:
- Detailed audit report
- Risk grading and prioritisation
- Clear remediation roadmap
- Board-ready executive summary
We can conduct reviews on-site or remotely and align scope to risk exposure.
2. Payment Facilitator Oversight
For acquiring principals and scheme members, Payment Facilitators introduce additional complexity and scheme risk.
We support with:
- Merchant onboarding control reviews
- High-risk sector exposure analysis
- Transaction monitoring effectiveness testing
- Chargeback and fraud oversight assessment
- PCI DSS governance review
- Card scheme compliance alignment
- Ongoing monitoring framework design
Whether you require an independent PF audit, questionnaire validation, or control testing, we provide structured, defensible oversight.
3. Oversight Framework Design & Enhancement
If you are building or strengthening your oversight model, we help design:
- Risk-based monitoring matrices
- Agent risk scoring methodologies
- Oversight registers
- Annual audit programmes
- Trigger event review frameworks
- Board MI templates
- Escalation and remediation processes
Our approach is proportionate, practical, and aligned to supervisory expectations.
When This Becomes Critical
Oversight gaps often surface during:
- FCA supervisory engagement
- Change in control applications
- Safeguarding audits
- Rapid agent expansion
- Card scheme reviews
- Internal audit findings
Having a structured, independent oversight framework materially reduces regulatory and reputational risk.
How We Work
We typically operate under one of three models:
Annual Independent Oversight Review
A full structured review programme with board reporting.
Targeted Thematic Review
Focused review (AML, safeguarding, PF controls, etc.).
Ongoing Oversight Partner
Quarterly or periodic monitoring support with embedded advisory access.
Why Payment Practice
- Specialist focus on payments and e-money
- Deep understanding of FCA supervisory expectations
- Independent, credible third-party perspective
- Proportionate, risk-based methodology
- Board-level reporting
- Practical remediation support
We understand the balance principals must strike: avoiding over-engineering while ensuring defensible compliance.