On the 9 July 2020 the Financial Conduct Authority (FCA ) published additional guidance for payment and e-money institutions. This followed a consultation that involved more than 60 organisations including payment firms, trade associations, compliance consultancies and law firms.
The purpose is to strengthen firms’ prudential risk management and arrangements for safeguarding customers’ funds. Whilst these temporary measures have come about as a result of Covid-19, the new guidance is expected to be incorporated into the FCA ‘s approach document for payment and e-money institutions when they consult on further changes later during 2020/21.
Our Coronavirus and safeguarding customer funds checklist is designed to help payment and e-money institutions consider whether their current compliance policies, procedures, systems and processes meet the new guidelines. The FCA expects senior management to take “all reasonable steps” to ensure compliance. These are what we think are the reasonable steps you should be taking.
Download checklist
Related resources
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Risk Management and Wind-Down Planning in E-Money and Payment Firms: FCA Multi-Firm Review
Working Together: the FCA and ICO help firms to use AI responsibly
Talking Regulation: Regulators revise Memorandum of Understanding in relation to payments in the UK
Webinar: Consumer Duty Board Report 2025