26 June 2026 · 6 min read
Safeguarding remains the highest-impact control in a payments or e-money firm. It is also the area where we most often find gaps between the written policy and daily practice.
Segregation must be immediate and complete
Relevant funds should reach a designated safeguarding account by the end of the business day following receipt. Mixed flows, delayed sweeps and fee deductions taken from the safeguarding account are recurring findings.
Reconcile daily, and reconcile properly
An internal ledger position must be compared against the external account balance every business day, with breaks investigated and resolved within a defined window. Keep evidence of who performed and who reviewed each reconciliation.
Paperwork that is easy to forget
Acknowledgement letters from safeguarding credit institutions, an up-to-date safeguarding policy, a wind-down plan that explains how funds would be returned, and an annual safeguarding audit are all now standard supervisory expectations.
