Conduct, Safeguarding & Financial Promotions

W1b
How firms must treat customers and protect their funds — Consumer Duty, safeguarding and the promotions regime.
155Jurisdictions
97Moved this cycle
738Sourced findings
W1bModule

Every jurisdiction World Payments Monitor tracks for W1b, with the standing position recorded in the current weekly cycle. Each entry links to the full module on that jurisdiction’s page, where the sourced findings and evidence sit.

Africa

AFRHigh5 sourced findings

Safeguarding across the bloc rests on client-fund segregation/trust mechanisms rather than a harmonised EU-style CASS regime. South Africa's new framework for the first time enables non-banks to hold client funds with segregation and minimum capital; Nigeria… Full module →

Algeria

DZHigh5 sourced findings

The PSP regime pairs licensing with conduct and safeguarding obligations: no overdrafts/interest, bank guarantees/professional liability insurance, transparent contracts and secure authentication.

Argentina

ARConfirmed4 sourced findings

Safeguarding for PSPCPs is strict: 100% of customer funds must be held at all times in peso sight accounts at Argentine financial institutions, individualised per customer, available on demand and segregated from the PSP's own funds. PSPs may not treat… Full module →

Asia-Pacific

APACConfirmed4 sourced findings

APAC safeguarding mechanisms are typically segregation/trust/bank-guarantee for non-bank PSPs, supervised by the national authority. Singapore mandates safeguarding of customer monies under the PS Act; India requires escrow-only settlement; Australia's… Full module →

Australia

AUHigh4 sourced findings

Australia's Corporations Amendment (Digital Assets Framework) Bill 2025 has received Royal Assent, extending the AFSL licensing perimeter to digital asset platforms and tokenised custody platforms, running alongside the Treasury Laws Amendment (Payments… Full module →

Austria

ATConfirmed5 sourced findings

Safeguarding of payment-service-user and e-money-holder funds is anchored in ZaDiG 2018 Art.18/19 and the E-GeldG 2010. Conduct supervision of banks, payment institutions and e-money institutions has been centralised since 2025 in a dedicated FMA division… Full module →

Bangladesh

BDHigh5 sourced findings

Customer fund safeguarding for MFS/PSP operates through a bank-custody model (Trust Fund/mobile-account float held with scheduled banks) rather than a segregated-trust EMI model. Conduct oversight runs through Bangladesh Bank's Customer Interest Protection… Full module →

Belgium

BEConfirmed6 sourced findings

Safeguarding of client/e-money funds is governed by Articles 42 and 194 of the Law of 11 March 2018 (transposing PSD2 Article 10), enforced via NBB circulars; conduct-of-business and consumer-facing rules sit in Book VII of the Code of Economic Law, enforced… Full module →

Brazil

BRAssessed4 sourced findings

Brazil's safeguarding regime requires payment institutions to segregate client/end-user funds from proprietary assets and supports traceability and auditability; e-money balances are held in payment accounts with prudential treatment. BCB Rule 80/2021 sets… Full module →

Bulgaria

BGHigh5 sourced findings

Safeguarding for Bulgarian PIs/EMIs follows the PSD2/EMD2-aligned segregation model under the PSPSA. PSD3/PSR reform will add a central-bank safeguarding option and merge the EMI category into 'payment institution authorised to issue e-money'; Bulgaria has… Full module →

Cambodia

KHHigh6 sourced findings

Conduct and consumer-facing obligations for payment institutions sit across several instruments: the NBC's dedicated Prakas on Resolution of Consumer Complaints, a 2021 circular tightening KYC and tiered daily transaction limits for PSPs and Bakong… Full module →

Cameroon

CMConfirmed6 sourced findings

Consumer/conduct protection rests on the CEMAC-wide Regulation No 01/20/CEMAC/UMAC/COBAC (2020) on protection of banking-product consumers, layered on Cameroon's national Consumer Protection Law (2011) and Banking Secrecy Law (2003). Safeguarding of e-money… Full module →

Canada

CAConfirmed4 sourced findings

Under the RPAA, PSPs must safeguard end-user funds and manage operational risk; the Bank of Canada published a final Safeguarding of Funds supervisory guideline (December 12, 2024). The BoC's mandate is supervisory rather than direct consumer protection. MSBs… Full module →

Canada – Alberta

CA-ABConfirmed5 sourced findings

Conduct and safeguarding obligations for Alberta-touching payment activity are set federally via the RPAA safeguarding-of-funds framework and provincially via the Gift Card Regulation and High-Cost Credit Regulation under the Consumer Protection Act.

Canada – British Columbia

CA-BCConfirmed5 sourced findings

Conduct and safeguarding for BC-touching payment activity is set primarily at the federal level via the RPAA's end-user fund safeguarding framework (in force since September 8, 2025) and the FCAC-overseen Code of Conduct for the Credit and Debit Card… Full module →

Canada – New Brunswick

CA-NBConfirmed5 sourced findings

Safeguarding of end-user funds for RPAA-registered PSPs is now governed by the Bank of Canada's final safeguarding guideline; provincially, NB credit union deposits are protected via the New Brunswick Credit Union Deposit Insurance Corporation (NBCUDIC) up to… Full module →

Canada – Ontario

CA-ONConfirmed6 sourced findings

PSPs holding end-user funds must maintain a Bank of Canada-approved safeguarding framework (in force since September 8, 2025) alongside an operational risk-management framework; the voluntary but FCAC-monitored Code of Conduct governs merchant-facing conduct… Full module →

Canada – Quebec

CA-QCConfirmed6 sourced findings

Safeguarding of end-user funds under the RPAA became a binding obligation as of September 8, 2025, per the Bank of Canada's final safeguarding guideline; conduct/consumer-facing protections in Quebec run in parallel through the Consumer Protection Act (Bill… Full module →

Chile

CLHigh4 sourced findings

Safeguarding for non-bank prepaid issuers rests on statutory segregation under Ley 20.950: customer funds must be accounted for and held segregated, are ring-fenced from issuer obligations, and may not be attached for the issuer's own debts… Full module →

China (mainland)

CNConfirmed5 sourced findings

Safeguarding rests on mandatory 100% centralised deposit of customer reserve funds with PBOC/designated banks, cleared via NetsUnion (NUCC); conduct duties codified in the 2024 Implementation Rules; draft antitrust regime remains unresolved.

Colombia

COHigh4 sourced findings

Financial-consumer conduct is governed primarily by Ley 1328 de 2009 (the financial consumer protection statute) and the SFC's Sistema de Atención al Consumidor Financiero (SAC), with each supervised entity required to have an independent Defensor del… Full module →

Costa Rica

CRHigh4 sourced findings

Consumer/depositor protection rests on the Deposit Guarantee Fund Law (No. 9816) for private banks, SUGEF's disclosure/advertising regulation (SUGEF 10-07), and general consumer-protection law administered via the National Consumer Commission. State-owned… Full module →

Croatia

HRConfirmed6 sourced findings

Safeguarding of payment service users' and e-money holders' funds is governed by a dedicated HNB Decision under Article 35/100 of the Electronic Money Act/Payment System Act, alongside a HNB-run complaints and ADR regime and consumer-protection oversight. The… Full module →

Curaçao

CWHigh5 sourced findings

CBCS conduct supervision rests on a 2017 complaints-handling Regulation applicable to all supervised institutions, backstopped by a bank deposit guarantee scheme (up to 50,000 XCG per depositor per bank) and a running series of public warning notices. A… Full module →

Cyprus

CYConfirmed4 sourced findings

Safeguarding of user funds (segregation or insurance/guarantee) is mandated under the EMI/PI laws, with CBC adopting EBA safeguarding guidance (EBA/GL/2018/05). In 2025-2026 the CBC issued new directives strengthening EMI/PSP governance, capital and… Full module →

Czech Republic

CZHigh5 sourced findings

Client-fund safeguarding for Czech PIs/EMIs follows the PSD2/EMD2 segregation model (payment accounts for defined transactions only for PIs; broader e-money storage for EMIs), documented via internal AML/safeguarding policies reviewed by the CNB during… Full module →

Denmark

DKHigh6 sourced findings

Safeguarding of e-money-institution client funds is governed by Executive Order no. 722 of 24/6/2011 on the Safeguarding of Funds Received by Electronic Money Institutions, sitting alongside the Payments Act and the general Financial Business Act… Full module →

Dominican Republic

DOConfirmed5 sourced findings

Financial-consumer conduct governed by the Reglamento de Protección al Usuario (2015), enforced via SB's ProUsuario; a World-Bank-assisted overhaul was published for consultation March 2026.

Ecuador

ECConfirmed5 sourced findings

Conduct and safeguarding obligations run through the Superintendencia de Bancos' consumer-protection framework, anchored by a mandatory per-entity Defensor del Cliente, codified financial-consumer rights, and point-of-sale anti-skimming/card-visibility rules.

Egypt

EGConfirmed4 sourced findings

Conduct and safeguarding flow from Law 194/2020 and CBE rules. Licensed institutions must lodge an irrevocable, unconditional, auto-renewing bank letter of guarantee in favour of the CBE equal to 2% of paid-up/allocated capital, usable by the CBE to impose… Full module →

Estonia

EEHigh5 sourced findings

Safeguarding follows the standard EMD2/PSD2 approach overseen by Finantsinspektsioon with EBA outsourcing guidance adopted; consumer conduct splits between Finantsinspektsioon and the Consumer Protection and Technical Regulatory Authority.

European Economic Area

EEAConfirmed4 sourced findings

Conduct, safeguarding and consumer-facing rules across the EEA derive from PSD2's conduct provisions (transposed nationally) and will shift to the directly-applicable Payment Services Regulation (PSR) once adopted. Safeguarding of user funds is achieved by… Full module →

Finland

FIConfirmed5 sourced findings

FIN-FSA and Consumer Ombudsman jointly police conduct/safeguarding/promotions; IPR VoP applies from Oct 2025 to all PSPs, PI/EMI instant-payment deadlines fall Jan/Jul 2027.

France

FRConfirmed5 sourced findings

Safeguarding for French PIs/EMIs follows PSD2/EMD2 segregation: client funds placed in a dedicated segregated account at a credit institution (or central bank / low-risk liquid assets), separate from the institution's own funds, with changes to the protection… Full module →

Germany

DEConfirmed4 sourced findings

Safeguarding of customer/e-money funds is mandated by §§17–18 ZAG: funds must either be segregated in an insolvency-proof trust account or in liquid low-risk assets, or covered by insurance/guarantee from an insurer or credit institution. Conduct rules flow… Full module →

Ghana

GHConfirmed5 sourced findings

Conduct, safeguarding and promotions sit under Act 987 and a stack of BoG guidelines. E-money float must be denominated in cedis with CDD/KYC tiers; corporate governance, disclosure/transparency and consumer-recourse guidelines bind PSPs and DEMIs. The… Full module →

Gibraltar

GIConfirmed4 sourced findings

Safeguarding is governed by the Financial Services (Electronic Money) Regulations 2020 (Regs 31-32: segregation option 1 / insurance-or-guarantee option 2), with safeguarded funds forming a priority asset pool on an insolvency event. Conduct is governed by… Full module →

Greece

GRConfirmed5 sourced findings

Safeguarding for PIs/EMIs is set under Law 4021/2011 and BoG Executive Committee Act 164/2/13.2.2019, alongside professional indemnity insurance requirements for PISPs/AISPs under Law 4537/2018. Conduct obligations run via BoG Governor's Act 2501/2002 and the… Full module →

Hong Kong

HKConfirmed3 sourced findings

Conduct and safeguarding of SVF licensees are governed by HKMA guidelines issued under s.54 PSSVFO. SVF licensees must maintain AML/CFT systems and meet supervisory expectations set out in the Guideline on Supervision of SVF Licensees. There is no single… Full module →

Hungary

HUHigh4 sourced findings

Hungary's safeguarding regime requires EMI/PI client-asset segregation in protected accounts under MNB oversight, backed by periodic inspections and administrative sanction/licence-revocation powers; the MNB additionally issues supervisory recommendations on… Full module →

Iceland

ISHigh4 sourced findings

Conduct-of-business and safeguarding obligations for Icelandic PSPs/EMIs sit within Act 114/2021's PSD2-derived framework, supplemented by GDPR-based data-protection duties and Consumer Agency oversight of general consumer legislation, with FME/CBI… Full module →

India

INConfirmed4 sourced findings

Customer-fund safeguarding for both PAs and non-bank PPI issuers rests on a mandatory escrow account held with a single scheduled commercial bank, with no co-mingling, day-end balance floors, and quarterly statutory-auditor certification. For escrow purposes… Full module →

Indonesia

IDConfirmed5 sourced findings

Under the PS Act and Payment Services Regulations, MPIs that hold customer money or issue e-money must safeguard relevant moneys through one of three MAS-approved methods: an undertaking/guarantee by a Singapore bank or prescribed financial institution, a… Full module →

Ireland

IEConfirmed4 sourced findings

Safeguarding of consumer funds is a CBI 'key priority': PI/EMI firms must segregate consumer funds in a separate account with an EEA-authorised bank OR cover them with an insurance/guarantee policy, per PSD2/EMD2 as implemented through the PSR 2018, EMR 2011… Full module →

Isle of Man

IMConfirmed6 sourced findings

Conduct and safeguarding for Class 8 licenceholders sit under the Financial Services Rule Book (FSRB) made under FSA08, supervised by the IOMFSA with a risk-based, proportionate inspection regime; there is no standalone Consumer Duty-style rulebook comparable… Full module →

Italy

ITConfirmed5 sourced findings

Safeguarding for Italian IPs/IMELs that also conduct non-payment business is achieved via a mandatory ring-fenced 'patrimonio destinato' under Art.114-terdecies TUB. Conduct and transparency supervision sits with Banca d'Italia under the TUB's transparency… Full module →

Ivory Coast (UEMOA bloc)

CIConfirmed4 sourced findings

Conduct and safeguarding obligations for PIs/EMIs are set at the UEMOA level. Payment institutions must join the regional Professional Association of Payment and Electronic Money Institutions within one month of approval; e-money float must be segregated and… Full module →

Japan

JPConfirmed4 sourced findings

Safeguarding for non-bank FTSPs is achieved primarily through a Performance Security Deposit (cash deposit with the Legal Affairs Bureau), with bank performance bonds and trust arrangements as alternatives; crypto/EPI custody requires segregation. The FSA… Full module →

Kazakhstan

KZHigh5 sourced findings

Conduct regulation is being substantially rebuilt under the pending New Banking Law, which introduces behavioural supervision, mandatory suitability/disclosure duties, and a unified pretrial dispute-resolution ombudsman. Agent liability and joint-and-several… Full module →

Kenya

KEConfirmed4 sourced findings

Safeguarding of customer/e-money funds in Kenya is achieved through a mandatory trust structure: PSPs must establish a trust with a CBK-licensed bank to hold customer funds, supported by a trust deed required under the NPS Act. Conduct and consumer… Full module →

Laos

LAHigh5 sourced findings

Conduct and consumer-facing safeguarding obligations for payment/financial services flow from the Decree on Consumer Protection regarding Financial Services No. 225/GOV (2020), which elaborates the Law on Commercial Banks' complaint-handling duties, plus… Full module →

Latin America

LATAMConfirmed4 sourced findings

Member-state conduct/safeguarding regimes attach to the licence. In Brazil, PIs may freely move balances customers hold on prepaid payment accounts and fund their settlement (PI) accounts at the BCB, with consumer-protection/transparency rules applying; the… Full module →

Latvia

LVConfirmed5 sourced findings

Safeguarding mandated under Section 38 (EMD2 Art.10 transposition) via segregation or insurance/guarantee, daily reconciliation, annual external audit; CRPC handles general consumer law, Latvijas Banka handles financial conduct/fund-protection as 2026… Full module →

Liechtenstein

LIConfirmed5 sourced findings

Safeguarding of client funds is mandated for PIs/EMIs under the ZDG/EGG regime with prior FMA notification of material changes; conduct oversight sits with the same integrated FMA supervisor responsible for prudential matters. Financial-promotion enforcement… Full module →

Lithuania

LTConfirmed4 sourced findings

EMIs/PIs must safeguard client funds either by segregation in a separate account at a credit institution (Lithuania, another Member State, or the Bank of Lithuania) or by investing in secure, liquid, low-risk assets, or via insurance/guarantee. The Bank of… Full module →

Luxembourg

LUConfirmed4 sourced findings

CSSF Circular 26/906 (published 20 Jan 2026, effective 30 Jun 2026) consolidates safeguarding into dedicated chapter 8 with daily reconciliations, strict segregation and a designated management-body member; three-lines-of-defence governance, two authorised… Full module →

Macau SAR

MOHigh5 sourced findings

Client-fund safeguarding for Macau payment institutions is structurally embedded in the licence-tiering itself (the 'non-bank credit institution' route triggers when funds are invested/used) rather than a standalone safeguarding rulebook. Conduct/complaint… Full module →

Malaysia

MYConfirmed5 sourced findings

Safeguarding of customer funds is the central conduct mechanism. Non-bank e-money issuers (EMIs) must place collected funds in segregated trust/dedicated deposit accounts with licensed banking institutions, used only to refund users and pay merchants… Full module →

Malta

MTHigh4 sourced findings

Safeguarding anchored in FIA Cap. 376, S.L. 376.04 and MFSA FI Rules (segregation, shortfall liability); MFSA Conduct Rules. PSD3/PSR post-trilogue: final compromise texts 23 Apr 2026, ECON adoption recommended 18 May 2026, OJ publication expected Q2-Q3 2026… Full module →

Mexico

MXConfirmed4 sourced findings

IFPE safeguarding/conduct rests on the Fintech Law and secondary regulations (notably Banxico Circular 12/2018 and the 2021 IFPE Provisions). IFPEs may not pay interest on client balances (Art. 29) and must segregate/manage client electronic funds under… Full module →

Morocco

MAConfirmed4 sourced findings

Conduct and consumer-protection for payment/credit customers rests on Law 103-12 and consumer-protection Law 31-08, both enforced by Bank Al-Maghrib, which issues transparency, complaint-handling and banking-mediation rules. Customer funds at payment… Full module →

Mozambique

MZHigh6 sourced findings

BdM directly supervises market conduct of all credit institutions, financial companies and IMEs via Notices (e.g. 8/GBM/2021 on contractual terms/transparency, 9/GBM/2020 on complaints handling) issued under Law 20/2020. Depositor protection runs through a… Full module →

Myanmar

MMHigh5 sourced findings

Safeguarding of MFS customer float is mandated via segregated trust/deposit accounts at partner commercial banks with daily reconciliation duties, tiered KYC limits, and CBM suspension/revocation powers for non-compliance. Post-coup, conduct enforcement has… Full module →

Nepal

NPHigh5 sourced findings

Safeguarding operates through mandatory settlement-bank arrangements rather than a dedicated trust/segregation regime; conduct obligations flow from the Financial Consumer Protection and Grievance Management Procedure, 2020 and NRB's annually revised Unified… Full module →

Netherlands

NLConfirmed4 sourced findings

Safeguarding of payment service users' funds is implemented in the Wft via PSD2/EMD2, with two mechanisms: segregation (a third-party-funds foundation or, since 2022, a quality account) or an insurance/comparable guarantee. AFM supervises conduct and… Full module →

New Zealand

NZConfirmed4 sourced findings

Conduct is governed by the FMC Act 2013 and the CoFI regime (Financial Markets (Conduct of Institutions) Amendment Act 2022), with FMA as conduct regulator requiring fair conduct programmes. There is no EMI-style statutory safeguarding/segregation regime… Full module →

Nigeria

NGHigh4 sourced findings

Conduct and safeguarding for Nigerian PSPs flow from the structural rule that only MMOs/PSBs hold customer funds, plus the CBN Consumer Protection Regulation 2019 and Consumer Protection Framework 2016. MMO customer balances are held in nominee/trust-style… Full module →

Norway

NOConfirmed5 sourced findings

Safeguarding of client/e-money funds is codified in the Financial Institutions Act (protection of funds, prohibition on paying interest on e-money float, redemption rights) and detailed in the Financial Institutions Regulations; conduct and market-promotion… Full module →

Pakistan

PKConfirmed7 sourced findings

Customer-fund safeguarding via mandatory segregated Trust Account; Branchless Banking Regulations place ultimate agent liability on the principal institution; conduct sits within PS&EFT Act 2007 and SBP's BC&CPD.

Panama

PAAssessed4 sourced findings

Panama has no dedicated conduct-of-business or safeguarding regime for non-bank payment/e-money providers; consumer and conduct protection for banking relationships defaults to the SBP and ACODECO under general banking and consumer-protection law, with AML… Full module →

Peru

PEConfirmed5 sourced findings

Safeguarding of e-money funds is via mandatory fideicomiso (trust) arrangements under Ley 29985 art.6, supervised by SBS. Conduct governed by SBS Res. 3274-2017, amended by Res. 01689-2025, backstopped by updated infractions regime under Res. 01029-2026… Full module →

Philippines

PHHigh4 sourced findings

Consumer conduct and safeguarding rest on the Financial Products and Services Consumer Protection Act (RA 11765) administered by the BSP, plus BSP IT-risk and fraud-monitoring requirements (Circular 1140) and fit-and-proper authority over directors/officers… Full module →

Poland

PLHigh4 sourced findings

Conduct/safeguarding obligations flow from the UUP (PSD2/EMD transposition) under KNF supervision. PSPs must safeguard client funds (segregated accounts / equivalent), maintain AML compliance functions, hold civil-liability insurance/guarantee for PIS, and… Full module →

Portugal

PTConfirmed5 sourced findings

Safeguarding of PI/EMI client funds follows the PSD2 Article 10 segregation-or-insurance model, supervised by Banco de Portugal alongside its broader banking conduct supervision mandate. BdP has tightened internal-control and governance expectations via… Full module →

Qatar

QAConfirmed4 sourced findings

PSP customer funds are safeguarded via segregated client-money/escrow accounts; non-bank e-money issuers and merchant acquirers must perform an independent audit on the clients' money (escrow) account every six months and report to QCB. Conduct rules require… Full module →

Romania

ROConfirmed4 sourced findings

Conduct and safeguarding for Romanian PIs/EMIs follow PSD2/EMD2 as transposed by Laws 209/2019 and 210/2019, supervised by the BNR. Safeguarding rests on Article 10 PSD2-style segregation (separate account at a credit institution or low-risk liquid assets, or… Full module →

Russia

RUHigh5 sourced findings

Consumer/conduct supervision sits with the Bank of Russia's Service for Consumer Protection and Financial Inclusion, which handles reactive complaint-driven supervision and proactive identification of unfair market practices (mis-selling, misinformation on… Full module →

Rwanda

RWConfirmed4 sourced findings

Customer-fund safeguarding via trust-account segregation at a licensed Rwandan commercial bank; Reg 54/2022 e-money safeguards; Reg 89/2025 (+ 17 Sept 2025 Directive) FX-promotion conduct enforcement.

Saudi Arabia

SAConfirmed4 sourced findings

Conduct and safeguarding for KSA PSPs sit within the Implementing Regulation of the Law of Payments and Payment Services, which includes dedicated parts on consumer protection, financial inclusion, e-money issuance/redemption, outsourcing and risk. EMIs must… Full module →

Senegal

SNHigh4 sourced findings

EMI safeguarding via Instruction n°008-05-2015 (75% demand-deposit float rule); 2025 Banking Law adds Financial Innovation Laboratory and agent framework.

Serbia

RSHigh5 sourced findings

Safeguarding of PI/EMI client funds is governed by dedicated NBS decisions on governance, internal controls and safeguarding of payment-service-user/e-money-holder funds. Financial promotions and complaint handling are separately regulated by NBS decisions on… Full module →

Singapore

SGHigh4 sourced findings

Safeguarding of customer monies for MPIs is achieved via a bank/financial-institution undertaking or guarantee, a trust account deposit, or other MAS-prescribed means. MPIs face base-capital and security-deposit obligations, fit-and-proper criteria, and… Full module →

Slovakia

SKConfirmed5 sourced findings

NBS enforces conduct and consumer-protection rules on top of the PSD2/EMD2 licensing perimeter, including fund-safeguarding (own-funds floor for EMIs) and active sanctioning of unfair commercial/fee practices at supervised banks and financial intermediaries… Full module →

Slovenia

SIConfirmed4 sourced findings

Safeguarding follows the standard PSD2/EMD2 segregation model (client funds held in a separate account with an authorised credit institution or invested in liquid assets), supervised by Banka Slovenije; limited-network and telecom exclusions from ZPlaSSIED… Full module →

South Africa

ZAHigh4 sourced findings

Conduct and consumer-protection supervision is split under the Twin Peaks model: the SARB Prudential Authority (PA) is the prudential supervisor and the Financial Sector Conduct Authority (FSCA) is the market-conduct authority, both operating under the… Full module →

South Korea

KRConfirmed4 sourced findings

Safeguarding for prepaid/e-money was materially strengthened by the EFTA amendment (passed Aug 2023) and Enforcement Decree, effective 15 September 2024: prepayment providers must separately manage 100% of advance payments via trust or payment-guarantee… Full module →

Spain

ESConfirmed5 sourced findings

RD 712/2010 safeguarding template plus BdE/SEPBLAC June-2025 proportionality guidance on account restriction/closure.

Sri Lanka

LKConfirmed5 sourced findings

Market-conduct supervision was formalised for the first time in Sri Lanka via the Financial Consumer Protection Regulations No. 01 of 2023, administered by CBSL's FCRD; retail-payment-service PSPs offering payment initiation/account-information services must… Full module →

Sweden

SEConfirmed5 sourced findings

Safeguarding of client funds is a mandatory business-plan element for PIs/EMIs under FI's FFFS 2010:3/2018:4/2011:49 regulatory code. Conduct rules extend to online payment-method display (2020 amendment to the Payment Services Act) and, from 2026, a full… Full module →

Switzerland

CHConfirmed4 sourced findings

Conduct and client-onboarding rules flow from the Financial Services Act (FinSA/FIDLEG) (client segmentation, suitability, prospectus) and AMLA. Safeguarding is not via an EU-style segregation/insurance regime: FinTech-licensed deposits are NOT covered by… Full module →

Taiwan

TWHigh4 sourced findings

Stored electronic-payment funds must be held in bank-provided dedicated escrow accounts under the E-Payment Act, financial consumer conduct is governed separately by the Financial Consumer Protection Act, and the FSC has taken direct enforcement action… Full module →

Tanzania

TZHigh4 sourced findings

Safeguarding of customer e-money in Tanzania is structured around a mandatory trust arrangement: non-bank e-money issuers must establish a separate legal entity (a trust) and maintain a trust account for customer funds under the Payment System (Electronic… Full module →

Thailand

THConfirmed4 sourced findings

Conduct and safeguarding obligations for designated payment providers flow from BOT notifications under the PSA, covering governance, IT-risk, consumer protection, KYC, and customer-fund handling, supplemented by the Consumer Protection Act, Electronic… Full module →

Tunisia

TNConfirmed5 sourced findings

Payment institutions' conduct, safeguarding and consumer-protection obligations are set out in BCT Circular 2018-16, which mandates professional liability insurance/bank guarantee cover, tiered payment-account ceilings, a ring-fenced 'compte global' held with… Full module →

Turkey

TRConfirmed4 sourced findings

Safeguarding under Law No. 6493 requires e-money issuers to convert received funds into e-money without delay and to hold customer funds in segregated, blocked bank accounts at Law No. 5411 banks during the term of use, separate from the institution's own… Full module →

Uganda

UGConfirmed6 sourced findings

Safeguarding under the NPSA operates via a 100%-backed trust/special account model: e-money issuers must hold customer funds one-for-one in liquid assets in a trust account (non-bank issuers) or special account (financial institutions), supervised by BoU. The… Full module →

Ukraine

UAHigh5 sourced findings

Consumer/conduct oversight sits with the NBU's Office for Financial Services Consumer Rights Protection (formal mandate since a 2019 law made Ukraine the 120th country to protect financial-services consumers); safeguarding of consumer funds for non-financial… Full module →

United Arab Emirates

AEConfirmed4 sourced findings

Onshore conduct and safeguarding flow from the SVF Regulation and RPSCS Regulation, supervised by the CBUAE Consumer Protection function. SVF licensees must protect customer float (segregation / additional capital floor mechanisms), maintain an Additional… Full module →

United Kingdom

UKConfirmed5 sourced findings

On 30 June 2026 the FCA published its final cryptoasset rules and guidance (including stablecoin issuance), completing its Crypto Roadmap. Rules apply to firms authorised under FSMA on/after 25 October 2027; the authorisation gateway opens 30 September 2026… Full module →

United States

USHigh4 sourced findings

The US lacks a unified safeguarding regime equivalent to UK CASS or EEA PSD2. State MTLs impose 'permissible investments' requirements: licensees must hold qualifying liquid assets equal to outstanding payment obligations, backed by surety bonds and minimum… Full module →

United States – Alabama

US-ALHigh5 sourced findings

HB303 (Cryptocurrency Kiosk Fraud Prevention Act) was enacted and signed by Governor Kay Ivey, effective October 1, 2026, imposing receipts, refund mechanisms, consumer support lines, fraud warnings, $1,000/day-$10,000/month transaction caps, and… Full module →

United States – Alaska

US-AKConfirmed5 sourced findings

Safeguarding runs through statutory trust/permissible-investments rules (AS 06.55.501 et seq.), with strict segregation of customer funds from licensee assets — including virtual currency, which cannot be rehypothecated. DBS actively enforces this: it denied… Full module →

United States – Arizona

US-AZConfirmed5 sourced findings

Arizona's safeguarding regime requires authorized delegates to hold transmitted funds in trust for the licensee, mandates GAAP-audited annual financials, and requires quarterly Reports of Condition. Consumer-facing conduct rules require licensees to disclose… Full module →

United States – Arkansas

US-ARHigh7 sourced findings

Safeguarding is achieved through the Money Services Act's Permissible Investments article and surety-bond/net-worth regime rather than a segregation-of-funds trust model. The ASD Legal Section supervises conduct via examinations, no-action letters and… Full module →

United States – California

US-CAConfirmed4 sourced findings

California protects payment-service users through a net-worth/surety-bond safeguarding model under the MTA and a broad conduct regime under the California Consumer Financial Protection Law (CCFPL), which empowers the DFPI to police unlawful, unfair, deceptive… Full module →

United States – Colorado

US-COConfirmed5 sourced findings

Colorado's money-transmission safeguarding regime relies on permissible-investment/surety-bond trust protection for payment-instrument holders, coupled with MTMA customer-protection provisions (timely forwarding, receipts, refunds, plain-language disclosure)… Full module →

United States – Connecticut

US-CTConfirmed4 sourced findings

Connecticut requires licensees to maintain permissible investments held in statutory trust for customers (PA 13-253); PA 25-66 (effective Oct 1 2025) narrows virtual-currency custody delegation, tightens FDIC-insurance-related promotional claims, and adds… Full module →

United States – Delaware

US-DEConfirmed5 sourced findings

Safeguarding for money transmitters is achieved through mandatory surety bonds/irrevocable letters of credit and statutory receipt/disclosure duties (5 Del.C. §§ 2309, 2313). Conduct and promotions are policed generally through the Consumer Fraud Act… Full module →

United States – District of Columbia

US-DCHigh5 sourced findings

DC's conduct/safeguarding regime rests on MTA bonding/net-worth requirements plus the general Consumer Protection Procedures Act (CPPA); DISB's Enforcement and Consumer Protection Division investigates conduct violations, and the OAG has begun actively… Full module →

United States – Florida

US-FLConfirmed5 sourced findings

Conduct standards sit across Chapter 560 recordkeeping/AML duties, the state's general deceptive-practices statute (FDUTPA), and dedicated telemarketing/solicitation statutes (Florida Telemarketing Act and the FTSA 'mini-TCPA') that regulate promotional… Full module →

United States – Georgia

US-GAConfirmed5 sourced findings

Safeguarding rests on a surety-bond-plus-liquid-clearing-account model. Georgia enacted its first comprehensive privacy statute, SB 111 (Act 462), signed May 11, 2026, with substantive provisions effective July 1, 2026. A contested 'debanking' bill… Full module →

United States – Hawaii

US-HIConfirmed6 sourced findings

Safeguarding of transmitted funds rests on HRS 489D's permissible-investments/statutory-trust and bonding requirements, with authorized-delegate contract discipline and a full formal-enforcement toolkit (cease-and-desist, consent orders, civil/criminal… Full module →

United States – Idaho

US-IDConfirmed5 sourced findings

Idaho's safeguarding mechanism for money transmitters is a scaled security device (surety bond, irrevocable letter of credit, or similar), not a UK/EU-style client-money segregation or trust regime. Conduct/promotions are governed generically by the Idaho… Full module →

United States – Illinois

US-ILConfirmed5 sourced findings

IDFPR's conduct and safeguarding framework combines a Dodd-Frank-styled Consumer Financial Protection Law giving IDFPR UDAAP-style enforcement powers over unlicensed and licensed financial-services providers, with DACPA-specific customer-asset-safeguard… Full module →

United States – Indiana

US-INConfirmed6 sourced findings

Conduct/safeguarding obligations sit in the MTMA plus the new Indiana Earned Wage Access Act (EWAA), effective 2026-01-01.

United States – Iowa

US-IAConfirmed5 sourced findings

Iowa's money-transmission conduct regime sits inside Chapter 533C (permissible investments as a safeguarding proxy, timely-transmission and disclosure duties, payroll-processing disclosures) and is layered with the state's general Consumer Fraud Act (Iowa… Full module →

United States – Kansas

US-KSConfirmed5 sourced findings

Kansas ties licensee conduct to permissible-investment/trust safeguarding of outstanding transmission liability, a dedicated information-security statute mirroring the federal GLBA Safeguards Rule, a 2024 Earned Wage Access conduct regime under OSBC, and a… Full module →

United States – Kentucky

US-KYHigh6 sourced findings

Kentucky's safeguarding mechanism for money transmitters is trust-fund treatment of agent-commingled proceeds under KRS 286.11-037, backstopped by DFI's complaint/investigation and licence-suspension powers (KRS 286.11-055). General conduct oversight runs… Full module →

United States – Louisiana

US-LAConfirmed6 sourced findings

Louisiana's conduct/safeguarding regime for payments rests on trust-fund treatment of transmitted proceeds under the Sale of Checks and Money Transmission Act, a statutory 10-business-day transmission/return obligation, an explicit anti-forfeiture protection… Full module →

United States – Maine

US-MEConfirmed5 sourced findings

Safeguarding runs through MMTMA's surety-bond/permissible-investment regime, layered with an outright card-surcharge ban and new 2025 kiosk disclosure, infosec, and unhosted-wallet-control obligations.

United States – Maryland

US-MDConfirmed5 sourced findings

Maryland's conduct regime for EWA moves from HB1294 (2025, tipping permitted with disclosure) to SB94 (2026, tipping banned), effective October 1, 2026.

United States – Massachusetts

US-MAConfirmed5 sourced findings

Safeguarding under c.169B requires permissible investments equal to 100% of outstanding transmission obligations, held in a defined set of high-quality liquid assets. Consumer-facing conduct is governed by DOB remittance-disclosure rules and a strict… Full module →

United States – Michigan

US-MIHigh4 sourced findings

Safeguarding rests on a permissible-investments requirement backed by surety bond, with DIFS examination/confidentiality powers under Section 26. The pending MTMA bill would introduce a statutory trust mechanism over permissible investments for customer… Full module →

United States – Minnesota

US-MNConfirmed7 sourced findings

Minnesota's conduct regime layers virtual-currency-kiosk-specific consumer safeguards (disclosure, refund and transaction-limit rules under Ch. 53B) onto a general Deceptive Trade Practices Act fee-transparency overlay (2025 surcharge disclosure amendment)… Full module →

United States – Mississippi

US-MSConfirmed6 sourced findings

Safeguarding under Mississippi's money-transmission regime is bond- and permissible-investment-based rather than trust/segregation-based. The 2026 legislative session added the first dedicated conduct/cybersecurity duties for licensees (Data Security for… Full module →

United States – Missouri

US-MOConfirmed6 sourced findings

Safeguarding is bond/net-worth based rather than trust/segregation based; conduct/promotions rules newly extended in 2025 via the Virtual Currency Kiosk Consumer Protection Act.

United States – Montana

US-MTConfirmed5 sourced findings

Conduct/safeguarding runs through activity-specific bonding (escrow $100k; debt management $50k) with MUTPCPA as UDAP backstop, strengthened by SB488 (2025).

United States – Nebraska

US-NEConfirmed5 sourced findings

Safeguarding for Nebraska money transmitters rests on statutory net-worth/permissible-investment requirements plus a surety bond (minimum $100,000, scaling with liability). Conduct obligations include refund processing, receipt requirements, and (as of LB609… Full module →

United States – Nevada

US-NVConfirmed5 sourced findings

Safeguarding of transmitted funds in Nevada rests on the NRS 671 surety-bond/permissible-investment regime rather than a segregation-trust mandate; general conduct and promotional practices are policed under NRS Chapter 598, enforced by the Attorney General's… Full module →

United States – New Hampshire

US-NHConfirmed4 sourced findings

Safeguarding under RSA 399-G rests on prudential net-worth and permissible-investment requirements plus the surety bond, with recordkeeping/complaint-handling obligations; the Banking Department retains cease-and-desist, consent-order and revocation powers.

United States – New Jersey

US-NJConfirmed5 sourced findings

Safeguarding is achieved through a mandatory surety bond/letter-of-credit and net-worth requirements rather than segregation; conduct is policed via the CFA, with the AG signalling aggressive enforcement on fee/disclosure practices.

United States – New Mexico

US-NMConfirmed6 sourced findings

NM safeguarding mechanism is the statutory security instrument (surety bond/LC) under NMSA 58-32-203, not segregation/trust; general conduct backstop via Unfair Practices Act and Data Breach Notification Act.

United States – New York

US-NYConfirmed4 sourced findings

NY safeguarding for money transmitters rests on Banking Law §651 permissible-investment cover (liquid assets at least equal to outstanding payment instruments/traveler's checks) plus a surety bond of at least $500,000 (increasable by the Superintendent)… Full module →

United States – North Carolina

US-NCConfirmed5 sourced findings

Safeguarding rests on a statutory permissible-investments/trust mechanism plus bond/net-worth backstops; conduct is policed principally via the state's UDTPA (Ch.75) with parallel AG/NCCOB enforcement authority.

United States – North Dakota

US-NDConfirmed5 sourced findings

Safeguarding for ND money transmitters rests on a permissible-investments/net-worth-and-bond model rather than pure customer-fund segregation. A new cybersecurity/data-security statute (HB 1127, effective Aug 1, 2025) imposes conduct-adjacent… Full module →

United States – Ohio

US-OHConfirmed5 sourced findings

Safeguarding of customer funds under the Ohio MTL regime rests on the permissible-investments/trust mechanism (ORC 1315.06) plus the security device (ORC 1315.07), with continuing licensee duties under ORC 1315.05. The Superintendent holds graduated… Full module →

United States – Oklahoma

US-OKConfirmed4 sourced findings

Safeguarding for Oklahoma money transmitters rests on the surety-bond model rather than segregation/trust requirements. Conduct and disclosure obligations have been substantially modernized in 2025-2026 via the digital asset kiosk law (consumer… Full module →

United States – Oregon

US-ORConfirmed5 sourced findings

Oregon's safeguarding mechanism for money transmitters is a security device (surety bond or equivalent) rather than a segregation/trust regime, backstopped by DFR examination authority and licence-revocation powers. Conduct and marketing practices generically… Full module →

United States – Pennsylvania

US-PAHigh4 sourced findings

Pennsylvania has no dedicated payments-conduct/safeguarding regulator akin to CASS; conduct obligations for money transmitters and payment firms flow through DoBS licensing conditions (BSA/AML/IT/disaster-recovery audit plans, advertising restrictions) and… Full module →

United States – Rhode Island

US-RIConfirmed5 sourced findings

Conduct and safeguarding obligations for RI currency transmission licensees are codified in RI Gen. Laws 19-14.3-3.5 through 3.9, covering mandatory customer disclosures, prohibited acts (fraud, BSA/EFTA non-compliance, deceptive advertising), and… Full module →

United States – South Carolina

US-SCHigh5 sourced findings

Safeguarding for SC-licensed money transmitters rests on a surety-bond/net-worth regime rather than segregation-of-funds trust. Conduct/promotions rules are emerging fastest around VC kiosks via pending Bill 4592.

United States – South Dakota

US-SDConfirmed5 sourced findings

Safeguarding for South Dakota money transmitters rests on a tiered surety bond plus a statutory trust/permissible-investments requirement matching outstanding transmission liabilities. Consumer-facing conduct is anchored by the 36% APR rate cap on… Full module →

United States – Tennessee

US-TNHigh5 sourced findings

Safeguarding in Tennessee runs through the MTMA's net-worth/surety-bond regime (not trust/segregation-style safeguarding as in EMI regimes). Conduct and promotions oversight blends TDFI licensing conditions with the Tennessee Consumer Protection Act, enforced… Full module →

United States – Texas

US-TXHigh4 sourced findings

Texas has no segregation/trust-account safeguarding regime akin to EU/UK client-money rules; consumer protection is instead delivered through minimum net-worth and surety-bond requirements, TDB supervisory oversight, and marketing/advertising restrictions… Full module →

United States – Utah

US-UTHigh5 sourced findings

Safeguarding for Utah money transmitters rests on minimum net worth plus a surety bond, with DFI discretion to compel deposits if a licensee is unsafe or unsound. Conduct/promotions oversight for consumer fees (including surcharges) sits with the Division of… Full module →

United States – Vermont

US-VTConfirmed5 sourced findings

Vermont safeguards customer funds via statutory trust over permissible investments (eff. July 2024), mandatory surety bond, and prudential net-worth standards, plus new 2025 kiosk fraud-refund obligations.

United States – Virginia

US-VAConfirmed5 sourced findings

Virginia has no dedicated e-money safeguarding regime; consumer protection runs through the surety bond mechanism plus VCPA enforcement. A mandatory-fee/surcharge disclosure statute (SB 1212) took effect July 1, 2025.

United States – Washington

US-WAConfirmed5 sourced findings

Washington's conduct regime centres on a named Responsible Individual per licensee, mandatory permissible-investment/safeguarding of customer funds, a statutory refund right, and federal Regulation E remittance-transfer disclosure obligations layered on top… Full module →

United States – West Virginia

US-WVConfirmed5 sourced findings

Safeguarding for WV payments licensees is delivered through the statutory surety-bond/permissible-investment mechanism rather than a segregation-of-funds trust regime. Conduct enforcement runs through the Commissioner's cease-and-desist, consent-order and… Full module →

United States – Wisconsin

US-WIConfirmed5 sourced findings

Safeguarding rests on a surety bond/permissible-investments model, with new consumer conduct obligations on virtual currency kiosk operators via 2025 Act 226.

United States – Wyoming

US-WYHigh5 sourced findings

Wyoming's safeguarding regime for money transmitters rests on permissible-investment requirements (cash, CDs, securities, Treasuries) equal to outstanding obligations, backed by a surety bond, with annual audited statements. For SPDI/bank digital-asset… Full module →

Uruguay

UYConfirmed4 sourced findings

Safeguarding of IEDE customer funds is legally mandated via segregated trust-style accounts at licensed IIFs (Ley 19.210 art. 5), with fiduciary responsibility on the IEDE and BCU discretion over liquid-asset placement. Conduct/promotions oversight sits with… Full module →

Venezuela

VEAssessed4 sourced findings

Conduct and safeguarding obligations sit mainly in SUDEBAN's fintech resolution (performance bonds, risk-management controls) and a dedicated banking-complaints reconsideration body (Defensoría del Cliente y Usuario Bancario). Broader price/consumer-fairness… Full module →

Vietnam

VNConfirmed5 sourced findings

Safeguarding for e-money is delivered via a 1:1 payment-assurance (escrow) account model: e-wallet providers must hold a payment-assurance account at an associated bank and may not receive cash directly from customers. Decree 52/2024 introduced Vietnam's… Full module →

Zambia

ZMHigh5 sourced findings

Conduct/safeguarding rules sit in BoZ directives under BFSA s.167 and NPSA-derived e-money directives, supplemented by a weak voluntary Bankers Association Code; BoZ consumer-protection capacity remains thin.