Money Remittance & Deliverable FX

Money Remittance & Deliverable FX are among the most common regulated payment activities in the UK. Firms operating in this space are primarily providing payment services, not investment services, and are therefore regulated by the FCA under the Payment Services Regulations 2017 (PSRs) rather than under the investment regime.

While “deliverable FX” is often used to describe the commercial activity of exchanging and settling currencies, it is not a regulatory permission in its own right. In regulatory terms, most deliverable FX firms are authorised as payment institutions, typically for money remittance, alongside other relevant payment services depending on how the business operates in practice.

AuthoriPay specialises in helping firms obtain FCA authorisation for money remittance and deliverable FX activities, and in supporting them operationally through access to FX liquidity, safeguarding accounts, and ongoing compliance support.

Money Remittance and Deliverable FX – How the FCA Views These Activities

Money remittance is a defined payment service under the PSRs. It involves receiving funds from a payer and transmitting a corresponding amount to a payee, often cross-border and frequently involving currency exchange.

Deliverable FX is best understood as a commercial model of providing money remittance, where:

• Currency exchange is performed,

• The currency is deliverable and settled,

• The transaction facilitates a genuine payment (rather than speculative trading).

In practice, most deliverable FX firms are providing money remittance services, but many also carry on additional regulated payment activities that require further permissions under the PSRs.

FCA Permissions – Getting the Scope Right

A common issue for deliverable FX firms is under-scoping their FCA permissions.

In addition to money remittance, many firms also:

• Issue payment instruments (for example, through online portals, client logins, or non-face-to-face payment instructions), and/or

• Operate payment accounts where client funds are held on account and used for multiple transactions over time.

Each of these activities is separately regulated under the PSRs and requires the appropriate permissions.

AuthoriPay helps firms:

• Map their actual operating model to the correct PSR permissions

• Apply for FCA authorisation or a Variation of Permission (VoP) where required

• Address the associated regulatory capital and governance requirements

FCA Authorisation Support

We provide end-to-end support for firms seeking FCA authorisation for money remittance and deliverable FX activities, including:

• Regulatory scoping and permission analysis

• Preparation and submission of FCA applications

• Business plans, financial forecasts, and capital assessments

• AML, governance, and compliance frameworks

• Ongoing engagement with the FCA throughout the application process

We work with both start-ups and established firms looking to regularise or expand their permissions.

Safeguarding of Client Funds

Safeguarding is a core regulatory requirement for payment and FX firms. Firms must ensure that relevant client funds are protected in accordance with the PSRs.

For deliverable FX businesses, safeguarding can be complex, particularly where funds are received in advance of FX settlement or onward payment.

AuthoriPay assists firms with:

• Identifying which funds are required to be safeguarded

• Designing compliant safeguarding structures

• Drafting safeguarding policies and reconciliation procedures

• Preparing firms for FCA reviews and audits

We also support firms in preparing for the enhanced safeguarding regime expected to apply from 2026.

Safeguarding Accounts and Banking Support

One of the most significant practical challenges for FX and remittance firms is securing suitable banking arrangements.

We support firms with:

• Opening safeguarding accounts

• Structuring trust or client money arrangements

• Engaging with UK and international banking partners

• Ongoing safeguarding oversight and reporting

This support continues beyond authorisation, ensuring firms remain operational and compliant as they grow.

FX Liquidity and Operational Readiness

Authorisation alone is not enough for a successful FX or remittance business. Firms must also be operationally ready.

AuthoriPay helps firms:

• Access FX liquidity providers

• Structure agency or match-principal models

• Align liquidity arrangements with regulatory expectations

• Avoid inadvertently straying into investment or MiFID-regulated activity

Our approach ensures firms can operate commercially while remaining within the regulatory perimeter.

Electronic Money and Regulatory Boundaries

Some money remittance and FX business models can unintentionally fall within the scope of the Electronic Money Regulations (EMRs), particularly where funds are held on account without a clear onward payment instruction.

We help firms:

• Assess whether their activities constitute issuing electronic money

• Adjust operating models to remain within the PSRs where appropriate

• Apply for Electronic Money Institution authorisation where required

This reduces regulatory risk and ensures firms are correctly authorised for their activities.

MiFID Considerations for FX Firms

Certain FX forwards and derivative-style products may fall within the scope of MiFID if not structured correctly.

AuthoriPay can:

• Review FX product offerings and settlement models

• Advise on applicable exemptions

• Assist with MiFID authorisation where required

• Provide written regulatory opinions where appropriate

Why AuthoriPay

Key considerations for Start-Ups: