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.

Although a specific timeframe is not mentioned in the regulations, the industry standard is to conduct an AML audit annually. A firm’s banking providers will expect to see an annual audit covering all aspects of AML. Whilst the  FCA do not specify when an AML audit should be undertaken, they would look less favourably on firms that don’t perform this annually. AML Audits should be conducted by independent parties; therefore, it’s advisable to seek external support.

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.

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.

To improve an AML audit score, review the audit findings and rate each in order of importance. Create a remediation plan with actionable points for each finding and set a deadline for completion for each action. Assign an employee to oversee each action and another employee, typically the MLRO, to oversee the completion of the remediation plan. Schedule updates to policies, procedures, risk assessments, and training to match any amendments.