Safeguarding Account

Safeguarding & Banking

Safeguarding Account Opening & Banking Setup for Payment Institutions

Expert support establishing safeguarding accounts and operational banking — the two biggest practical challenges facing payment firms today.

Safeguarding & Banking — The Operational Bottleneck

Safeguarding accounts are a regulatory requirement for all authorised payment institutions and e-money institutions that hold customer funds — ensuring that in the event of the firm’s insolvency, customers can recover their money promptly and in full. Under the Payment Services Regulations 2017 and Electronic Money Regulations 2011, regulated firms must segregate customer funds in designated safeguarding accounts at approved credit institutions, separate from the firm’s own operating capital. Acumen Global Compliance supports regulated firms in establishing compliant Safeguarding Account arrangements — covering the selection of appropriate banking partners willing to open designated safeguarding accounts for payment institutions and EMIs, the structuring of your safeguarding method (segregation, insurance, or guarantee), the drafting of your safeguarding policy and procedures, the establishment of daily reconciliation processes, and the documentation of your safeguarding arrangements for FCA regulatory reporting. We also advise on the FCA’s evolving safeguarding expectations and help firms upgrade their arrangements to meet the enhanced requirements set out in the FCA’s safeguarding consultation.

Key Facts

Who needs this

APIs, EMIs and SPIs holding customer funds

Requirement

Mandatory under PSR 2017 Part 7

Timeline

4–8 weeks

Price from

Included in relevant service packages

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    Safeguard Your Account

    How We Help With Safeguarding & Banking

    Requirements Analysis

    Assess your specific safeguarding obligations based on licence type, transaction volumes, and how customer funds flow through your business.

    Bank Selection & Introduction

    Identify banks that actively serve payment institutions and introduce you with pre-prepared compliance packs — significantly improving acceptance rates.

    Documentation Preparation

    Compile AML policies, business plans, director documentation, financial projections, and FCA authorisation details in the format banks require.

    Account Opening Support

    Manage the account opening process, respond to bank due diligence queries, and negotiate account terms and fee structures.

    Reconciliation Framework

    Design and implement daily reconciliation procedures — the most common area where the FCA finds safeguarding deficiencies.

    Ongoing Safeguarding Compliance

    Monthly monitoring of safeguarding compliance, policy updates, and preparation for FCA safeguarding assessments.

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    What's Included

    Safeguarding requirements analysis

    Complete application documentation pack

    Daily reconciliation procedures and templates

    Reconciliation framework with escalation procedures

    Annual safeguarding review and policy update

    Banking partner introductions (3+ banks)

    Account agreement review and negotiation

    Safeguarding policy (PSR 2017 aligned)

    FCA safeguarding reporting templates

    Ongoing compliance monitoring

    FAQs

    Frequently Asked Questions

    A designated bank account that holds customer funds separately from the firm’s own money. If your firm becomes insolvent, safeguarded funds are protected and returned to customers. The FCA requires this for all firms holding customer funds under PSR 2017.
    All Authorised Payment Institutions (APIs) and E-Money Institutions (EMIs) must safeguard. Small Payment Institutions (SPIs) must safeguard if they hold customer funds overnight. The specific requirement depends on your licence type and how funds flow through your business.
    Banks face their own regulatory pressure regarding the clients they onboard. Many have de-risked by reducing their exposure to payment institutions — particularly MSBs serving high-risk corridors. Having proper compliance documentation and an expert introduction significantly improves acceptance rates.
    The FCA expects daily reconciliation of safeguarded funds against customer balances. This includes maintaining accurate records of amounts owed to each customer, reconciling against bank statements, and having clear procedures for identifying and resolving discrepancies within 24 hours.
    Alternative safeguarding methods under PSR 2017 include an insurance policy or guarantee from an authorised insurer or credit institution. We advise on all available options and help you implement the most practical solution for your business.
    The FCA conducts both routine supervisory assessments and thematic reviews of safeguarding. They examine: whether funds are segregated correctly, reconciliation frequency and accuracy, safeguarding policy adequacy, and the firm’s ability to return funds if it fails. Safeguarding has been an FCA supervisory priority since 2022.

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    Related Services

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    Full M&A advisory.

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    Full post-acquisition compliance.

    Banking Setup

    Support with Banking setup.

    Ready to Get Started?

    Book a free consultation to discuss your compliance needs with our specialist team.

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