Safeguarding Accounts

---

Payment and e-money firms that safeguard customer funds are required to have an appropriate safeguarding method in place in line with regulatory requirements set by the Financial Conduct Authority

Firms must safeguard relevant funds using one or a combination of the permitted methods, including segregated safeguarding bank accounts, investment in secure liquid assets, or insurance or comparable guarantees

The safeguarding method selected must be appropriate to the firm’s business model, transaction flows, currencies, scale and risk profile

In practice, many firms face significant challenges securing safeguarding arrangements, particularly with traditional banks

Common issues include long onboarding timelines, enhanced due diligence, limited appetite for payment and e-money firms, minimum balance requirements, and restrictions on certain business models or geographies

Firms operating in multiple currencies or across GBP, EUR and USD often face additional complexity, including the need for multiple safeguarding accounts or parallel arrangements

For some firms, access to secure liquid assets or insurance-based safeguarding is required where bank account solutions are unavailable or insufficient, adding further structuring and documentation challenges

We support firms in identifying and securing appropriate safeguarding solutions across all three permitted methods

We work with a wide network of safeguarding banks, custodians, insurers and liquidity providers with experience supporting payment and e-money firms

We help firms source segregated safeguarding accounts in GBP, EUR and USD, aligned to their regulatory status and operating model

Where appropriate, we assist with structuring safeguarding via secure liquid assets, including asset eligibility, custody arrangements and reconciliation frameworks

We also support insurance or guarantee-based safeguarding solutions where required, including introductions and regulatory alignment

We help prepare safeguarding narratives, fund-flow documentation and supporting materials required by banks, custodians and insurers during onboarding

Our support is designed to reduce onboarding friction, shorten timelines and ensure safeguarding arrangements are acceptable to both counterparties and the FCA