Neobank and Fintech Consultants.

Safeguarding typically involves placing client funds in a segregated account with a UK-authorised bank / Authorised Custodian or using an insurance policy. The firm must ensure daily reconciliation of safeguarded funds and protect them from co-mingling or insolvency risks. These measures, mandated under the Electronic Money Regulations 2011 and Payment Services Regulations 2017, ensure customer funds remain safe and recoverable at all times.

Joining a card scheme involves either becoming a direct scheme member or partnering with a principal member (e.g., a bank). Direct membership requires demonstrating financial stability, operational readiness, regulatory approval, and meeting scheme-specific risk, compliance, and technology standards. Fintechs often start by working with an issuing/acquiring partner to accelerate market entry while building capacity for future direct membership.

There is no fixed statutory timeframe for AML audits in the UK, but industry best practice is to carry out an independent AML review on an annual basis. In practice, regulators, banks and other key partners would expect this frequency and are likely to question firms that do not follow it. By contrast, the FCA is now mandating annual safeguarding audits for most payment and e-money firms under its enhanced safeguarding regime, making regular safeguarding audits a formal regulatory requirement rather than best practice.

No. After Brexit UK firms lost passporting rights into the EU. To operate in the EU, firms should either establish a licensed entity within an EU member state or partner with an already regulated EU firm. Many UK fintechs setup subsidiaries in Lithuania, although several years on it’s no longer the optimal location in Europe for an Emoney Licence.

The FCA set a very high bar. Applications are often rejected due to unclear business models, inadequate safeguarding arrangements, insufficient AML controls, or lack of experienced management. Missing documentation, weak financial forecasts, or lack of Consumer Duty knowledge can also contribute. The FCA expects thorough, well-documented applications with realistic plans, demonstrating how the firm will meet ongoing regulatory obligations and protect consumers.

We take a pragmatic approach to our audits. Our process typically starts with a gap analysis to identify any weaknesses in your framework, followed by a clear opportunity to implement any required changes before the final audit is completed. This approach allows issues to be addressed proactively, supports genuine improvement, and helps firms achieve a stronger audit outcome.