FCAFinalised Guidancelow

Payment and E-Money Institutions (general guidance)

In July 2020, the UK Financial Conduct Authority published finalised guidance providing temporary measures for payment institutions and e-money institutions regarding the safeguarding of customer funds amid the COVID-19 crisis. The guidance addressed prudential risk management practices intended to reduce the risk of consumer harm in the event of firm insolvency. While not an enforcement action, this supervisory guidance set expectations for how payment and e-money firms—including those operating BaaS-adjacent models—should manage safeguarded funds. No specific suspensions or enforcement actions against named firms were associated with this guidance, but it established a heightened supervisory posture for the sector.

Verified from source: The FCA published finalised guidance for payment institutions and e-money institutions on safeguarding customers' funds and strengthening prudential risk management during the COVID-19 pandemic, aimed at preventing harm to customers in the event of insolvency.

Implications
  1. Heightened FCA expectations for safeguarding customer funds at payment and e-money institutions
  2. Signals increased regulatory scrutiny of fintech and BaaS-adjacent firms in the UK during economic stress
  3. Firms failing to comply with safeguarding guidance could face future enforcement actions
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