--- title: "Conduct, Safeguarding & Financial Promotions (W1b) by jurisdiction — World Payments Monitor" canonical: https://payments.gi/modules/conduct-safeguarding-financial-promotions/ source_html: /modules/conduct-safeguarding-financial-promotions/index.html description: "Conduct, Safeguarding & Financial Promotions (W1b) across 154 jurisdictions: standing position, confidence and sourced findings for each, from the World Payments Monitor weekly cycle." generated_at: 2026-11-15T08:17:58Z content_sha256: 3f2b860f8ce98ef3e4e6a80e4d615f1e36dce430900588db575d2a365f386c70 generator: "fe-fleet/md-twin@1.0" --- # Conduct, Safeguarding & Financial Promotions W1b How firms must treat customers and protect their funds — Consumer Duty, safeguarding and the promotions regime. 154 Jurisdictions 2 Moved this cycle 1,211 Sourced findings W1b Module 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. Filter jurisdictions in W1b Moved this cycle Confirmed 105 Probable 49 154 of 154 ### Africa AFR Probable 5 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 →](https://payments.gi/jurisdictions/africa/#w1b-conduct-safeguarding-financial-promotions) ### Algeria DZ Probable 9 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 AR Confirmed 7 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 →](https://payments.gi/jurisdictions/argentina/#w1b-conduct-safeguarding-financial-promotions) ### Asia-Pacific APAC Confirmed 7 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 →](https://payments.gi/jurisdictions/asia-pacific/#w1b-conduct-safeguarding-financial-promotions) ### Australia AU Probable 7 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 →](https://payments.gi/jurisdictions/australia/#w1b-conduct-safeguarding-financial-promotions) ### Austria AT Confirmed 11 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 →](https://payments.gi/jurisdictions/austria/#w1b-conduct-safeguarding-financial-promotions) ### Bangladesh BD Probable 8 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 →](https://payments.gi/jurisdictions/bangladesh/#w1b-conduct-safeguarding-financial-promotions) ### Belgium BE Confirmed 8 sourced findings Safeguarding requirements remain largely PSD2-aligned; PSD3 adds an option for PIs to safeguard customer funds directly at a central bank (at that bank's discretion), mitigating fund-concentration risk. ### Brazil BR Probable 6 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 →](https://payments.gi/jurisdictions/brazil/#w1b-conduct-safeguarding-financial-promotions) ### Bulgaria BG Probable 8 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 →](https://payments.gi/jurisdictions/bulgaria/#w1b-conduct-safeguarding-financial-promotions) ### Cambodia KH Probable 9 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 →](https://payments.gi/jurisdictions/cambodia/#w1b-conduct-safeguarding-financial-promotions) ### Cameroon CM Confirmed 10 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 →](https://payments.gi/jurisdictions/cameroon/#w1b-conduct-safeguarding-financial-promotions) ### Canada CA Confirmed 7 sourced findings The Bank of Canada announced on June 12, 2026 that it will begin publishing Notices of Violation (NOVs) against PSPs, introducing a new public-enforcement-transparency mechanism into the RPAA conduct regime. ### Canada – Alberta CA-AB Confirmed 9 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-BC Confirmed 7 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 →](https://payments.gi/jurisdictions/canada-british-columbia/#w1b-conduct-safeguarding-financial-promotions) ### Canada – New Brunswick CA-NB Confirmed 8 sourced findings Bank of Canada published its final safeguarding-of-funds supervisory guideline clarifying PSP fund-protection obligations for nonbank PIs/EMIs serving New Brunswick end-users. ### Canada – Ontario CA-ON Confirmed 15 sourced findings PSP safeguarding obligations operative since September 8, 2025; Bank of Canada will begin publishing RPAA Notices of Violation from June 12, 2026, materially increasing conduct transparency. ### Canada – Quebec CA-QC Confirmed 6 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 →](https://payments.gi/jurisdictions/canada-quebec/#w1b-conduct-safeguarding-financial-promotions) ### Chile CL Probable 6 sourced findings CMF's Autenticación Reforzada de Clientes (ARC, NCG N°538) mandate took effect 1 August 2026, eliminating printed coordinate-card authentication except for a supervised, reported carve-out for digitally-excluded client groups; carve-out transactions are not… [Full module →](https://payments.gi/jurisdictions/chile/#w1b-conduct-safeguarding-financial-promotions) ### China (mainland) CN Confirmed 14 sourced findings China's Financial Product Online Marketing Management Rules (Announcement [2026] No. 9), jointly issued by PBOC and seven other bodies, entered into force on 30 September 2026, imposing a structured conduct regime on financial-product online marketing and… [Full module →](https://payments.gi/jurisdictions/china-mainland/#w1b-conduct-safeguarding-financial-promotions) ### Colombia CO Probable 7 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 →](https://payments.gi/jurisdictions/colombia/#w1b-conduct-safeguarding-financial-promotions) ### Costa Rica CR Probable 8 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 →](https://payments.gi/jurisdictions/costa-rica/#w1b-conduct-safeguarding-financial-promotions) ### Croatia HR Confirmed 8 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 →](https://payments.gi/jurisdictions/croatia/#w1b-conduct-safeguarding-financial-promotions) ### Curaçao CW Probable 7 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 →](https://payments.gi/jurisdictions/curacao/#w1b-conduct-safeguarding-financial-promotions) ### Cyprus CY Confirmed 6 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 →](https://payments.gi/jurisdictions/cyprus/#w1b-conduct-safeguarding-financial-promotions) ### Czech Republic CZ Probable 8 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 →](https://payments.gi/jurisdictions/czech-republic/#w1b-conduct-safeguarding-financial-promotions) ### Denmark DK Probable 10 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 →](https://payments.gi/jurisdictions/denmark/#w1b-conduct-safeguarding-financial-promotions) ### Dominican Republic DO Confirmed 7 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 EC Confirmed 7 sourced findings The BCE has progressively tightened authorisation and operating requirements for auxiliary payment systems via Resolution BCE-GG-024-2024 and the January 2026 SRP resolution BCE-GG-002-2026. ### Egypt EG Confirmed 6 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 →](https://payments.gi/jurisdictions/egypt/#w1b-conduct-safeguarding-financial-promotions) ### Estonia EE Probable 9 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 EEA Confirmed 11 sourced findings EEA conduct and safeguarding rules currently operate under PSD2 (Arts 10, 64–97) and EMD2 (Art 7) and will migrate to the directly-applicable Payment Services Regulation (PSR) from 2028. While the Instant Payments Regulation (Reg (EU) 2024/886) amended PSD2… [Full module →](https://payments.gi/jurisdictions/european-economic-area/#w1b-conduct-safeguarding-financial-promotions) ### Finland FI Confirmed 9 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 FR Confirmed 7 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 →](https://payments.gi/jurisdictions/france/#w1b-conduct-safeguarding-financial-promotions) ### Germany DE Confirmed 9 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 →](https://payments.gi/jurisdictions/germany/#w1b-conduct-safeguarding-financial-promotions) ### Ghana GH Confirmed 8 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 →](https://payments.gi/jurisdictions/ghana/#w1b-conduct-safeguarding-financial-promotions) ### Gibraltar GI Confirmed 17 sourced findings LN 2026/225, in force 16 July 2026, amended EMI safeguarding duties (reg 30), additional-activities limits (reg 32(3)), introduced a new safeguarding-option regime (reg 32A), and amended auditor-notification duties (reg 39(4), 39A) and Schs.4-5 of the… [Full module →](https://payments.gi/jurisdictions/gibraltar/#w1b-conduct-safeguarding-financial-promotions) ### Greece GR Confirmed 7 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 →](https://payments.gi/jurisdictions/greece/#w1b-conduct-safeguarding-financial-promotions) ### Hong Kong HK Confirmed 4 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 →](https://payments.gi/jurisdictions/hong-kong/#w1b-conduct-safeguarding-financial-promotions) ### Hungary HU Probable 6 sourced findings Buy-now-pay-later ('halasztott fizetés') services are moving out of a regulatory grey zone into Hungarian statute via an Amendment Act transposing EU Consumer Credit Directive 2 (Directive (EU) 2023/2225); reported to enter into force 20 November 2026… [Full module →](https://payments.gi/jurisdictions/hungary/#w1b-conduct-safeguarding-financial-promotions) ### Iceland IS Probable 4 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 →](https://payments.gi/jurisdictions/iceland/#w1b-conduct-safeguarding-financial-promotions) ### India IN Confirmed 12 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 →](https://payments.gi/jurisdictions/india/#w1b-conduct-safeguarding-financial-promotions) ### Ireland IE Confirmed 17 sourced findings Central-bank deposit option under PSR 2018 reg. 17 is unusable in practice following ECB Decision (EU) 2025/222 (applying from 9 April 2025); commercial-bank segregation, eligible-asset investment and insurance remain. Head of Safeguarding (PCF-56) controlled… [Full module →](https://payments.gi/jurisdictions/ireland/#w1b-conduct-safeguarding-financial-promotions) ### Isle of Man IM Confirmed 11 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 →](https://payments.gi/jurisdictions/isle-of-man/#w1b-conduct-safeguarding-financial-promotions) ### Italy IT Confirmed 8 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 →](https://payments.gi/jurisdictions/italy/#w1b-conduct-safeguarding-financial-promotions) ### Ivory Coast (UEMOA bloc) CI Confirmed 4 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 →](https://payments.gi/jurisdictions/ivory-coast-uemoa-bloc/#w1b-conduct-safeguarding-financial-promotions) ### Japan JP Confirmed 9 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 →](https://payments.gi/jurisdictions/japan/#w1b-conduct-safeguarding-financial-promotions) ### Kazakhstan KZ Probable 7 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 →](https://payments.gi/jurisdictions/kazakhstan/#w1b-conduct-safeguarding-financial-promotions) ### Kenya KE Confirmed 7 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 →](https://payments.gi/jurisdictions/kenya/#w1b-conduct-safeguarding-financial-promotions) ### Laos LA Probable 6 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 →](https://payments.gi/jurisdictions/laos/#w1b-conduct-safeguarding-financial-promotions) ### Latin America LATAM Confirmed 4 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 →](https://payments.gi/jurisdictions/latin-america/#w1b-conduct-safeguarding-financial-promotions) ### Latvia LV Confirmed 7 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 →](https://payments.gi/jurisdictions/latvia/#w1b-conduct-safeguarding-financial-promotions) ### Liechtenstein LI Confirmed 8 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 →](https://payments.gi/jurisdictions/liechtenstein/#w1b-conduct-safeguarding-financial-promotions) ### Lithuania LT Confirmed 10 sourced findings The Bank of Lithuania's revised Resolution No 247 safeguarding/governance regime (internal control, risk management, protection of received funds) has applied in full since 1 January 2026, alongside the wind-down-plan requirement (in force since 9 April 2025)… [Full module →](https://payments.gi/jurisdictions/lithuania/#w1b-conduct-safeguarding-financial-promotions) ### Luxembourg LU Confirmed 8 sourced findings CSSF governance/risk-management convergence for PI/EMI moved into force this cycle: the compliance deadline under Circular CSSF 26/906 (consolidating central administration, internal governance and risk-management requirements) fell due 30 June 2026, and a… [Full module →](https://payments.gi/jurisdictions/luxembourg/#w1b-conduct-safeguarding-financial-promotions) ### Macau SAR MO Probable 8 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 →](https://payments.gi/jurisdictions/macau-sar/#w1b-conduct-safeguarding-financial-promotions) ### Malaysia MY Confirmed 8 sourced findings BNM's Technology Requirements Policy Document (TR PD) — a four-tier technology-governance framework for payment regulatees — was issued March 2026 (substantive effect 12 March 2027), overlapping the existing RMiT regime and newly capturing licensed… [Full module →](https://payments.gi/jurisdictions/malaysia/#w1b-conduct-safeguarding-financial-promotions) ### Malta MT Probable 16 sourced findings Malta EMIs must safeguard client e-money funds directly with EU credit institutions (FIR/03 bars intermediaries), with mandatory reconciliations and an annual safeguarding audit. DORA has applied to Malta-licensed EMIs/PIs since 17 January 2025. ### Mexico MX Confirmed 6 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 →](https://payments.gi/jurisdictions/mexico/#w1b-conduct-safeguarding-financial-promotions) ### Morocco MA Confirmed 6 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 →](https://payments.gi/jurisdictions/morocco/#w1b-conduct-safeguarding-financial-promotions) ### Mozambique MZ Probable 8 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 →](https://payments.gi/jurisdictions/mozambique/#w1b-conduct-safeguarding-financial-promotions) ### Myanmar MM Probable 7 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 →](https://payments.gi/jurisdictions/myanmar/#w1b-conduct-safeguarding-financial-promotions) ### Nepal NP Probable 9 sourced findings NRB issued a directive under Payment and Settlement Act 2019 s.45 requiring retroactive collection of shareholder/director/senior-management background and beneficial-ownership information for all licensed payment institutions; no corporate insider is exempt. ### Netherlands NL Confirmed 10 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 →](https://payments.gi/jurisdictions/netherlands/#w1b-conduct-safeguarding-financial-promotions) ### New Zealand NZ Confirmed 7 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 →](https://payments.gi/jurisdictions/new-zealand/#w1b-conduct-safeguarding-financial-promotions) ### Nigeria NG Probable 5 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 →](https://payments.gi/jurisdictions/nigeria/#w1b-conduct-safeguarding-financial-promotions) ### Norway NO Confirmed 5 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 →](https://payments.gi/jurisdictions/norway/#w1b-conduct-safeguarding-financial-promotions) ### Pakistan PK Confirmed 9 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 PA Probable 9 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 →](https://payments.gi/jurisdictions/panama/#w1b-conduct-safeguarding-financial-promotions) ### Peru PE Confirmed 14 sourced findings BCRP has moved from interoperability-only regulation to a broader rulebook governing payment-acceptance/aggregator firms' handling and settlement of merchant funds, with safeguarding, contract and fee conditions effective from 2027. ### Philippines PH Probable 6 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 →](https://payments.gi/jurisdictions/philippines/#w1b-conduct-safeguarding-financial-promotions) ### Poland PL Probable 6 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 →](https://payments.gi/jurisdictions/poland/#w1b-conduct-safeguarding-financial-promotions) ### Portugal PT Confirmed 8 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 →](https://payments.gi/jurisdictions/portugal/#w1b-conduct-safeguarding-financial-promotions) ### Qatar QA Confirmed 6 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 →](https://payments.gi/jurisdictions/qatar/#w1b-conduct-safeguarding-financial-promotions) ### Romania RO Confirmed 6 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 →](https://payments.gi/jurisdictions/romania/#w1b-conduct-safeguarding-financial-promotions) ### Russia RU Probable 8 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 →](https://payments.gi/jurisdictions/russia/#w1b-conduct-safeguarding-financial-promotions) ### Rwanda RW Confirmed 7 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 SA Confirmed 7 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 →](https://payments.gi/jurisdictions/saudi-arabia/#w1b-conduct-safeguarding-financial-promotions) ### Senegal SN Probable 9 sourced findings The BCEAO tightened and partially relaxed electronic-money safeguarding rules via Instruction n°020 of 8 October 2026: minimum demand-deposit share of e-money backing assets falls from 75% to 65%, with a lower-of-cost-or-market valuation rule; per-client… [Full module →](https://payments.gi/jurisdictions/senegal/#w1b-conduct-safeguarding-financial-promotions) ### Serbia RS Probable 7 sourced findings Serbia's Law on Interchange Fees and Special Operating Rules for Card-based Payment Transactions is subject to a new NBS-prepared draft amendment (mid-2026) introducing interchange fee caps for domestic and international card transactions, part of the… [Full module →](https://payments.gi/jurisdictions/serbia/#w1b-conduct-safeguarding-financial-promotions) ### Singapore SG Probable 13 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 →](https://payments.gi/jurisdictions/singapore/#w1b-conduct-safeguarding-financial-promotions) ### Slovakia SK Confirmed 5 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 →](https://payments.gi/jurisdictions/slovakia/#w1b-conduct-safeguarding-financial-promotions) ### Slovenia SI Confirmed 6 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 →](https://payments.gi/jurisdictions/slovenia/#w1b-conduct-safeguarding-financial-promotions) ### South Africa ZA Probable 5 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 →](https://payments.gi/jurisdictions/south-africa/#w1b-conduct-safeguarding-financial-promotions) ### South Korea KR Confirmed 11 sourced findings Korea's Electronic Financial Transactions Act (EFTA) amendment, promulgated 2025-12-16 and taking effect 2026-12-17, requires payment-gateway (PG) operators to externally manage 100% of unsettled merchant/user settlement funds (phased 60%->80%->100%) and… [Full module →](https://payments.gi/jurisdictions/south-korea/#w1b-conduct-safeguarding-financial-promotions) ### Spain ES Confirmed 10 sourced findings RD 813/2026 requires state-licensed online gambling operators to verify that the payment-method holder matches the gambling-account holder; a 6-month transitional period (to 28 April 2027) applies for players registered before 28 October 2026, during which… [Full module →](https://payments.gi/jurisdictions/spain/#w1b-conduct-safeguarding-financial-promotions) ### Sri Lanka LK Confirmed 9 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 →](https://payments.gi/jurisdictions/sri-lanka/#w1b-conduct-safeguarding-financial-promotions) ### Sweden SE Confirmed 9 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 →](https://payments.gi/jurisdictions/sweden/#w1b-conduct-safeguarding-financial-promotions) ### Switzerland CH Confirmed 7 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 →](https://payments.gi/jurisdictions/switzerland/#w1b-conduct-safeguarding-financial-promotions) ### Taiwan TW Probable 6 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 →](https://payments.gi/jurisdictions/taiwan/#w1b-conduct-safeguarding-financial-promotions) ### Tanzania TZ Probable 7 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 →](https://payments.gi/jurisdictions/tanzania/#w1b-conduct-safeguarding-financial-promotions) ### Thailand TH Confirmed 6 sourced findings Under the Emergency Decree, banks, e-money providers, digital-asset operators and telcos carry joint/pro-rata liability for technology-crime losses absent demonstrated compliance. BOT has added youth-specific transfer caps (rollout Sep-Oct 2026) atop the… [Full module →](https://payments.gi/jurisdictions/thailand/#w1b-conduct-safeguarding-financial-promotions) ### Tunisia TN Confirmed 12 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 →](https://payments.gi/jurisdictions/tunisia/#w1b-conduct-safeguarding-financial-promotions) ### Turkey TR Confirmed 8 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 →](https://payments.gi/jurisdictions/turkey/#w1b-conduct-safeguarding-financial-promotions) ### Uganda UG Confirmed 8 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 →](https://payments.gi/jurisdictions/uganda/#w1b-conduct-safeguarding-financial-promotions) ### Ukraine UA Probable 7 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 →](https://payments.gi/jurisdictions/ukraine/#w1b-conduct-safeguarding-financial-promotions) ### United Arab Emirates AE Confirmed 7 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 →](https://payments.gi/jurisdictions/united-arab-emirates/#w1b-conduct-safeguarding-financial-promotions) ### United Kingdom UK Confirmed 13 sourced findings The FCA Supplementary Safeguarding Regime (CASS 15, CASS 10A, SUP 3A, SUP 16.14A) has applied since 7 May 2026, introducing daily reconciliation, diversification review, independent audit and resolution-pack obligations for payment and e-money institutions. ### United States US Probable 5 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 →](https://payments.gi/jurisdictions/united-states/#w1b-conduct-safeguarding-financial-promotions) ### United States – Alabama US-AL Probable 8 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 →](https://payments.gi/jurisdictions/united-states-alabama/#w1b-conduct-safeguarding-financial-promotions) ### United States – Alaska US-AK Confirmed 8 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 →](https://payments.gi/jurisdictions/united-states-alaska/#w1b-conduct-safeguarding-financial-promotions) ### United States – Arizona US-AZ Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-arizona/#w1b-conduct-safeguarding-financial-promotions) ### United States – Arkansas US-AR Probable 9 sourced findings Arkansas Act 347 (HB 1517), signed 20 March 2025, establishes a standalone EWA regulatory regime; providers are deemed not to be lending/money-transmission/debt-collection if compliant. A federal EWA framework bill (Earned Wage Access Consumer Protection Act)… [Full module →](https://payments.gi/jurisdictions/united-states-arkansas/#w1b-conduct-safeguarding-financial-promotions) ### United States – California US-CA Confirmed 7 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 →](https://payments.gi/jurisdictions/united-states-california/#w1b-conduct-safeguarding-financial-promotions) ### United States – Colorado US-CO Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-colorado/#w1b-conduct-safeguarding-financial-promotions) ### United States – Connecticut US-CT Confirmed 9 sourced findings Sec. 36a-613 imposes detailed pre-account and pre-transaction disclosure duties on virtual-currency kiosk operators, extended by PA 25-66 to all virtual-currency transmitters and now under active enforcement (March 2026 licence suspension). ### United States – Delaware US-DE Confirmed 8 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 →](https://payments.gi/jurisdictions/united-states-delaware/#w1b-conduct-safeguarding-financial-promotions) ### United States – District of Columbia US-DC Probable 10 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 →](https://payments.gi/jurisdictions/united-states-district-of-columbia/#w1b-conduct-safeguarding-financial-promotions) ### United States – Florida US-FL Confirmed 5 sourced findings Florida enacted the first comprehensive US state-level licensing framework for payment stablecoin issuers (HB 175 / companion SB 314, now Ch. 2026-176), integrated into the existing Chapter 560 money-services-business regime and aligned with the federal… [Full module →](https://payments.gi/jurisdictions/united-states-florida/#w1b-conduct-safeguarding-financial-promotions) ### United States – Georgia US-GA Confirmed 8 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 →](https://payments.gi/jurisdictions/united-states-georgia/#w1b-conduct-safeguarding-financial-promotions) ### United States – Hawaii US-HI Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-hawaii/#w1b-conduct-safeguarding-financial-promotions) ### United States – Idaho US-ID Confirmed 7 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 →](https://payments.gi/jurisdictions/united-states-idaho/#w1b-conduct-safeguarding-financial-promotions) ### United States – Illinois US-IL Confirmed 7 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 →](https://payments.gi/jurisdictions/united-states-illinois/#w1b-conduct-safeguarding-financial-promotions) ### United States – Indiana US-IN Confirmed 9 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-IA Confirmed 6 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 →](https://payments.gi/jurisdictions/united-states-iowa/#w1b-conduct-safeguarding-financial-promotions) ### United States – Kansas US-KS Confirmed 6 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 →](https://payments.gi/jurisdictions/united-states-kansas/#w1b-conduct-safeguarding-financial-promotions) ### United States – Kentucky US-KY Probable 6 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 →](https://payments.gi/jurisdictions/united-states-kentucky/#w1b-conduct-safeguarding-financial-promotions) ### United States – Louisiana US-LA Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-louisiana/#w1b-conduct-safeguarding-financial-promotions) ### United States – Maine US-ME Confirmed 10 sourced findings Virtual currency kiosk operators must disclose material risks (including fraud/loss) and exchange rates before any kiosk transaction, per 32 M.R.S. §6168 (in force since 2025-06-12). ### United States – Maryland US-MD Confirmed 8 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-MA Confirmed 5 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 →](https://payments.gi/jurisdictions/united-states-massachusetts/#w1b-conduct-safeguarding-financial-promotions) ### United States – Michigan US-MI Probable 4 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 →](https://payments.gi/jurisdictions/united-states-michigan/#w1b-conduct-safeguarding-financial-promotions) ### United States – Minnesota US-MN Confirmed 12 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 →](https://payments.gi/jurisdictions/united-states-minnesota/#w1b-conduct-safeguarding-financial-promotions) ### United States – Mississippi US-MS Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-mississippi/#w1b-conduct-safeguarding-financial-promotions) ### United States – Missouri US-MO Confirmed 8 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-MT Confirmed 6 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-NE Confirmed 8 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 →](https://payments.gi/jurisdictions/united-states-nebraska/#w1b-conduct-safeguarding-financial-promotions) ### United States – Nevada US-NV Confirmed 7 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 →](https://payments.gi/jurisdictions/united-states-nevada/#w1b-conduct-safeguarding-financial-promotions) ### United States – New Hampshire US-NH Confirmed 6 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-NJ Confirmed 6 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-NM Confirmed 6 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-NY Confirmed 8 sourced findings New York's AG/Gaming Commission enforcement architecture now explicitly reaches crypto-adjacent platforms and prediction-market derivatives platforms (Kalshi, now escalated to a $36B civil suit) on an unlicensed-gambling theory. ### United States – North Carolina US-NC Confirmed 5 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-ND Confirmed 5 sourced findings Federal GENIUS Act implementation racing 18 July 2026 statutory deadline: joint FinCEN/OFAC AML-sanctions proposed rule (8 Apr 2026), FDIC custody rule (comments due 9 Jun 2026), Treasury 'substantially similar' NPRM gating state-qualified issuers including… [Full module →](https://payments.gi/jurisdictions/united-states-north-dakota/#w1b-conduct-safeguarding-financial-promotions) ### United States – Ohio US-OH Confirmed 5 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 →](https://payments.gi/jurisdictions/united-states-ohio/#w1b-conduct-safeguarding-financial-promotions) ### United States – Oklahoma US-OK Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-oklahoma/#w1b-conduct-safeguarding-financial-promotions) ### United States – Oregon US-OR Confirmed 6 sourced findings Oregon closed a state-chartered-bank interest-rate-export (DIDMCA) loophole via HB 4116 (2026), reinforcing its 36% consumer-finance interest-rate cap against internet lenders partnering with out-of-state banks; DFR separately secured a $900,000 restitution… [Full module →](https://payments.gi/jurisdictions/united-states-oregon/#w1b-conduct-safeguarding-financial-promotions) ### United States – Pennsylvania US-PA Probable 7 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 →](https://payments.gi/jurisdictions/united-states-pennsylvania/#w1b-conduct-safeguarding-financial-promotions) ### United States – Rhode Island US-RI Confirmed 7 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 →](https://payments.gi/jurisdictions/united-states-rhode-island/#w1b-conduct-safeguarding-financial-promotions) ### United States – South Carolina US-SC Probable 10 sourced findings South Carolina enacted the Guarantee Banking Act (H.5538, SC Act No. 257), signed 2026-06-30, effective 2026-12-30, prohibiting financial institutions from discriminating in the provision of covered financial services on certain non-risk-based grounds and… [Full module →](https://payments.gi/jurisdictions/united-states-south-carolina/#w1b-conduct-safeguarding-financial-promotions) ### United States – South Dakota US-SD Confirmed 8 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 →](https://payments.gi/jurisdictions/united-states-south-dakota/#w1b-conduct-safeguarding-financial-promotions) ### United States – Tennessee US-TN Probable 5 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 →](https://payments.gi/jurisdictions/united-states-tennessee/#w1b-conduct-safeguarding-financial-promotions) ### United States – Texas US-TX Probable 6 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 →](https://payments.gi/jurisdictions/united-states-texas/#w1b-conduct-safeguarding-financial-promotions) ### United States – Utah US-UT Probable 5 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 →](https://payments.gi/jurisdictions/united-states-utah/#w1b-conduct-safeguarding-financial-promotions) ### United States – Vermont US-VT Confirmed 11 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-VA Confirmed 8 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-WA Confirmed 9 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 →](https://payments.gi/jurisdictions/united-states-washington/#w1b-conduct-safeguarding-financial-promotions) ### United States – West Virginia US-WV Confirmed 6 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 →](https://payments.gi/jurisdictions/united-states-west-virginia/#w1b-conduct-safeguarding-financial-promotions) ### United States – Wisconsin US-WI Confirmed 7 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-WY Probable 9 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 →](https://payments.gi/jurisdictions/united-states-wyoming/#w1b-conduct-safeguarding-financial-promotions) ### Uruguay UY Confirmed 8 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 →](https://payments.gi/jurisdictions/uruguay/#w1b-conduct-safeguarding-financial-promotions) ### Venezuela VE Probable 6 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 →](https://payments.gi/jurisdictions/venezuela/#w1b-conduct-safeguarding-financial-promotions) ### Vietnam VN Confirmed 6 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 →](https://payments.gi/jurisdictions/vietnam/#w1b-conduct-safeguarding-financial-promotions) ### Zambia ZM Probable 10 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. No jurisdiction matches those filters.