Safeguarding & Client Fund Protection
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Client fund segregation, ring-fencing, and safeguarding obligations across all active payment institution regimes. Coverage spans EU EMD2/PSD2 requirements, FCA CASS-15, and equivalent national rules. Sourced from W1b (Conduct, Safeguarding & Financial Promotions) — from its dedicated CASS-15 Safeguarding sub-strand where a jurisdiction has one, and from W1b conduct & safeguarding passages elsewhere — across the pipeline fleet.
CASS-15 Supplementary Safeguarding Regime
The UK operates a supplementary safeguarding regime for electronic money institutions (EMIs) and payment institutions (PIs) under the Electronic Money Regulations 2011 and the Payment Services Regulations 2017, with ongoing refinement via FCA PS25/12. Under CASS 15, regulated firms must segregate client funds in designated safeguarding accounts held at approved credit institutions or invested in qualifying assets. Annual audits of safeguarding compliance are required by the FCA; material shortfalls trigger supervisory engagement. The FCA's enhanced supervisory regime post-SVB UK (2023) resulted in increased scrutiny of EMI liquidity positions and safeguarding account verification. Enforcement actions in 2023–2024 included firm-level requirements and, in one case, voluntary wind-down proceedings where safeguarding deficiencies were identified.
Conduct, Safeguarding & Promotions
Stored value facility licensees must protect customer funds through an Additional Capital Float of at least 5% of total customer float, float segregation via escrow or restricted accounts with daily reconciliation, and AED 15 million minimum paid-up capital.
Outlook
As CBUAE's expanded 2025 Central Bank Law jurisdiction takes effect toward the 16 September 2026 dead
Conduct, Safeguarding & Financial Promotions
Safeguarding arrangements diverge sharply across the three core jurisdictions, and the bank-PSP versus non-bank-PI/EMI distinction is central. In South Africa, the SARB introduces a two-tier e-money regime: Tier 1 covers issuers above R5m monthly value with R8m capital, and Tier 2 covers those below R5m with R5m capital. The regime enables non-banks to hold cli
Conduct, Safeguarding & Promotions
Safeguarding models across the bloc diverge by mechanism, and the bank versus non-bank distinction matters: these obligations attach to non-bank PIs and EMIs rather than to deposit-taking banks. In Singapore, MPI holders must safeguard customers' monies via trust account, bank guarantee, or an undertaking by a safeguarding institution, with minimum paid-up capital of S$2
Conduct, Safeguarding & Promotions
Safeguarding is the binding conduct constraint on non-bank payment institutions in Argentina. PSPCP regulation (Com. "A" 6859, January 2020) requires 100% of customer funds to be held at all times in on-demand peso accounts at Argentine financial institutions, individualised per customer, available instantly on request, and segregated from the PSP's own funds; balances m
Conduct, Safeguarding & Financial Promotions
Austrian payment and e-money institutions carry safeguarding obligations as a condition of their FMA licence rather than as a freestanding rulebook. ZaDiG 2018 Article 18 requires safeguarding of payment-service-user funds, with organisational and due-diligence conditions under Article 20 and outsourcing conditions under Article 21 attached directly to the lice
Conduct, Safeguarding & Promotions
Tranche 1b of the payments modernisation reform delivers the customer-protection detail underneath the new licensing perimeter. Safeguarding is modelled on the Corporations Act client-money regime, adjusted for payments: the primary method is segregation of payment-related money in a separate trust account with an Australian ADI, with insurance or other prescribed method
Conduct, Safeguarding & Promotions
Customer fund safeguarding for MFS operates through a bank-custody model in which the scheduled bank's book balance must at all times equal the virtual balance of all registered mobile accounts, with banks liable for improper agent conduct - a bank-held custodial float model rather than a segregated-trust EMI arrangement. Bangladesh Bank has made mandatory the adoption o
Conduct, Safeguarding & Promotions
Safeguarding of client and e-money funds is governed by Articles 42 and 194 of the Law of 11 March 2018, transposing PSD2 Article 10, requiring segregation of funds in a distinct client account, global or individualised, held at an EU credit institution. An NBB circular permits an equivalent-safeguarding discharge where funds are instead protected by an EU-authorised int
Conduct, Safeguarding & Financial Promotions
Safeguarding for Bulgarian EMIs follows a PSD2/EMD2-aligned segregation model under the PSPSA; BNB Ordinance No.16 additionally mandates a Business Continuity Plan with geographically remote backup data centres and periodic failover testing. The proposed EU PSD3/PSR reform introduces a discretionary central-bank safeguarding-account option and a duty to avoid c
Conduct, Safeguarding & Financial Promotions
Brazil's conduct and safeguarding regime for payment institutions is built on BCB Rule 80/2021, which mandates segregation of client and end-user funds from proprietary assets, transparency and identification obligations, governance requirements, cybersecurity controls and service-continuity provisions. The safeguarding model is distinctive: rather than a UK/EU
Conduct, Safeguarding & Promotions
The live conduct item is safeguarding. The Bank of Canada published its final Safeguarding of Funds supervisory guideline on December 12, 2024, clarifying PSP obligations for safeguarding end-user funds; PSPs must hold risk-management and funds-safeguarding frameworks and submit an annual report. The mechanism is segregation, and the frameworks came into force from Septe
Conduct, Safeguarding & Promotions
From September 8, 2025, RPAA-registered payment service providers holding end-user funds, including Alberta PSPs, must safeguard those funds via a trust account, insurance or guarantee, placing funds in a segregated account no later than the end of the following business day; a segregated trust account is the default mechanism, with insurance or guarantee accepted as an
Conduct, Safeguarding & Financial Promotions
End-user fund safeguarding obligations under RPAA section 17 and RPAR came into force September 8, 2025, requiring PSPs serving BC end users to safeguard customer funds via trust account, insurance/guarantee, or a comparable prescribed mechanism. On surcharging, unlike Quebec, BC has no specific surcharge ban; BC merchants may surcharge subject to BPCPA disclos
Conduct, Safeguarding & Financial Promotions
Registered payment service providers holding end-user funds must maintain a Bank of Canada-approved safeguarding framework; the substantive obligation entered into force September 8, 2025 - distinct from the Retail Payment Activities Act's earlier November 1, 2024 registration-provision date - and the first PSP annual safeguarding report is due March 31, 2026.
Conduct, Safeguarding & Financial Promotions
Requirements to establish risk-management and funds-safeguarding frameworks under the RPAA came into force on September 8, 2025; PSPs must disclose use of a trust account or an insured/guaranteed account and log any shortfall instances with root-cause analysis. The final safeguarding guideline was published December 12, 2024, giving PSPs advance notice ahead of
Conduct, Safeguarding & Promotions
The live safeguarding item is a structural gap in the current non-bank regime. FinTech-licensed deposits are not covered by deposit protection; in bankruptcy, client assets are neither privileged nor protected, and clients must be warned (Banking Act Art. 1b para. 4 / Banking Ordinance Art. 7a). The Federal Council recognised this safeguarding gap as needing action in it
Conduct, Safeguarding & Financial Promotions
Conduct and safeguarding obligations for non-bank PIs and EMIs in Côte d'Ivoire are set regionally by the BCEAO. PIs and EMIs must join the regional Professional Association of Payment and Electronic Money Institutions within one month of approval and comply with AML/CFT, external financial relations, consumer-protection and data-protection rules. The safeguard
Conduct, Safeguarding & Financial Promotions
Customer-fund protection for non-bank payments operators in Chile rests on statutory segregation rather than deposit insurance, and this is the central conduct and safeguarding distinction between bank PSPs and non-bank PI/EMI operators. Under Ley 20.950 prepaid issuer funds received from the public may only be used for payments and refunds, must be accounted f
Conduct, Safeguarding & Financial Promotions
Cameroon's conduct and consumer-protection baseline for payments rests on CEMAC Regulation No 01/20/CEMAC/UMAC/COBAC (3 July 2020), which governs protection of banking-product consumers across the CEMAC zone, layered on Cameroon's national Consumer Protection Law No 2011/012 (6 May 2011) and Banking Secrecy Law No 2003/004 (21 April 2003). Together these three
Conduct, Safeguarding & Financial Promotions
The financial-consumer conduct regime is anchored by Ley 1328 de 2009, which establishes the financial-consumer protection regime. Art. 13 requires most SFC-supervised entities to maintain an independent Defensor del Consumidor Financiero handling complaints, conciliation and recommendations, operationalised via SFC circulars CE 015/2010 (SAC), CE 016/2010 and
Conduct, Safeguarding & Financial Promotions
State-owned banks in Costa Rica carry a full sovereign deposit guarantee via the Central Bank, while private-bank deposit protection is a distinct, less-standardised scheme under the Deposit Guarantee Fund Law No. 9816. Conduct and financial-promotions rules run through SUGEF 10-07 (the Regulation on Disclosure of Information and Advertising of Financial Produc
Conduct, Safeguarding & Promotions
Safeguarding of user funds — through segregation or insurance/guarantee cover — is mandated under the EMI/PI laws, with the CBC adopting EBA safeguarding guidance (EBA/GL/2018/05) and EBA authorisation guidance (EBA/GL/2017/09) for both application and ongoing supervision. The mechanism applies to non-bank PIs and EMIs, for which deposit protection does not apply; the se
Conduct, Safeguarding & Financial Promotions
Czech payment institutions operate under a narrower safeguarding mandate than electronic money institutions. PI funds may be held only in dedicated payment accounts for defined transaction execution, not for indefinite storage, a function reserved for EMIs, which carry broader stored-value safeguarding obligations under the segregation model. This bank/nonbank-
Conduct, Safeguarding & Financial Promotions
ZAG §§17-18 require PIs and EMIs to safeguard customer and e-money funds either by insolvency-proof segregation in a trust account or low-risk liquid assets, or by insurance or guarantee from an insurer or credit institution; §27 requires proper business organisation. PSD2 conduct rules (via ZAG and BGB §§675c ff.) cap payer card liability at EUR 50, mandate on
Conduct, Safeguarding & Financial Promotions
E-money institution client funds are safeguarded under Executive Order no. 722 of 24 June 2011, alongside the Payments Act and Financial Business Act; the European Commission's conformity assessment found Denmark's transposition of Directive 2009/110/EC largely conform with some partial-conformity gaps. Marketing and consumer-facing conduct is supervised by the
Conduct, Safeguarding & Financial Promotions
Financial-consumer conduct in the Dominican Republic is governed by the Reglamento de Protección al Usuario, adopted by the Junta Monetaria in 2015 and amended the same year, which sets out core financial-user rights. The implementing Instructivo, Circular CSB-REG-202400007, entered into force on 31 May 2024 and requires that consumers receive clear, non-mislea
Conduct, Safeguarding & Financial Promotions
Instruction 06-2025 pairs Algeria's new PSP licensing gate with a distinct conduct and safeguarding layer. PSPs must secure bank guarantees or, as an alternative, professional liability insurance to protect customer funds — a safeguarding mechanism functionally analogous to (though structured differently from) the trust-account and insurance approaches seen in
Conduct, Safeguarding & Financial Promotions
SB Resolution SB-2025-1876 (Aug 2025) governs postulation, verification, selection and designation of mandatory Defensores del Cliente at all public and private financial entities under SB control. Conduct rules also reach the point of sale: JPRM-2024-018-M's fifth transitional provision requires POS positioning so the cardholder can observe card insertion, swi
Conduct, Safeguarding & Financial Promotions
Finantsinspektsioon confirms that the EBA Guidelines on outsourcing arrangements (25 February 2019) — covering audit rights, data security and location, sub-outsourcing and exit strategies — apply to Estonian credit institutions, EMIs and PIs alike; this outsourcing baseline now sits underneath, and is being extended by, DORA. Consumer-facing conduct supervisio
Conduct, Safeguarding & Promotions
The conduct layer of the incoming EEA payments rulebook sits in the Payment Services Regulation, a directly-applicable Regulation carrying conduct-of-business rules — strong customer authentication, fraud liability, refunds, IBAN-name verification and open-banking API performance — that require no national transposition. Direct applicability is the analytically important
Conduct, Safeguarding & Financial Promotions
The Egyptian conduct and safeguarding layer carries a mechanism distinct from the segregation models familiar in the EU and UK. On licensing, an institution must provide an irrevocable, unconditional, final and automatically-renewing letter of guarantee in favour of the CBE equal to 2% of issued/paid-up or activity-allocated capital, which the CBE may use to im
Conduct, Safeguarding & Financial Promotions
FIN-FSA supervises all PSD2-regulated payment service providers in Finland, including third-party providers, which must be authorised or registered before commencing operations and appear on FIN-FSA's public register. The Instant Payments Regulation's compliance calendar carries corrected detail this cycle: payment institutions and e-money institutions must be
Conduct, Safeguarding & Promotions
Safeguarding is the live W1b pressure point for French non-bank PIs and EMIs. Funds received on behalf of users must be placed in dedicated account(s) at a credit institution, separately from the institution's own funds — and the ACPR notes that some firms struggle to find a credit institution willing to provide such a segregated account. Any change to the protection met
Conduct, Safeguarding & Financial Promotions
Conduct and safeguarding obligations are escalating. The BoG Corporate Governance Guidelines for PSPs (June 2025), issued under s.101(2)(j) of Act 987 and applicable to all licence categories, require boards of at least three members, a majority non-executive, with at least two resident in Ghana, against a compliance deadline of 31 December 2025. As of the 27 J
Conduct, Safeguarding & Promotions
The conduct, safeguarding and promotions perimeter for Gibraltar payments firms is anchored in three live instruments. On safeguarding, the Financial Services (Electronic Money) Regulations 2020 require EMIs to keep relevant funds segregated (option 1) or covered by insurance or guarantee (option 2), with insolvency-event provisions making safeguarded funds a priority as
Conduct, Safeguarding & Financial Promotions
Conduct and float protection for SVF licensees is delivered via HKMA guidelines under s.54 PSSVFO (the Guideline on Supervision of SVF Licensees) and the SVF minimum criteria, rather than through a single CASS-style safeguarding statute. Float protection is supervisory and criteria-based: there is no discrete statutory safeguarding instrument, and protection of
Conduct, Safeguarding & Promotions
The live conduct and safeguarding architecture for non-bank PI/EMI operators rests on the PS Act and the Payment Services Regulations. MPIs holding customer money or issuing e-money must safeguard relevant moneys via one of three MAS-approved methods: an undertaking or guarantee by a Singapore bank or prescribed FI (reg.15/16), a trust account or segregation of funds (re
Conduct, Safeguarding & Promotions
Conduct and safeguarding obligations are the live regulatory frontier for Ireland's non-bank PIs and EMIs. Irish PIs and EMIs must safeguard consumer funds either by segregation in a separate account with an EEA-authorised bank or by coverage under an insurance or guarantee policy, per PSD2 and EMD2 as implemented through the Central Bank (Supervision and Enforcement) Ac
Conduct, Safeguarding & Financial Promotions
Conduct obligations for Class 8 and other licenceholders sit under the Financial Services Rule Book 2016; Rule 8.16 requires the Authority's prior consent before a material function is outsourced, and per 2012 Guidance Note, outsourcing does not transfer regulatory responsibility to the third party. No FCA-Consumer-Duty-style rulebook exists in parallel. On the
Conduct, Safeguarding & Promotions
India's safeguarding model for non-bank PPI issuers and payment aggregators rests on a mandatory single-bank INR escrow account held with a scheduled commercial bank, with no co-mingling, a day-end balance floor not below outstanding PPIs plus acquirer dues, and quarterly statutory-auditor certification. The non-bank PPI issuer or PA is deemed a designated payment system
Conduct, Safeguarding & Financial Promotions
Conduct-of-business oversight for Icelandic payment services is split across three institutions rather than concentrated in a single conduct regulator: the Financial Supervisory Authority, now folded within the Central Bank of Iceland, supervises financial-sector conduct matters, the general Consumer Agency covers broader consumer legislation, and the Data Prot
Conduct, Safeguarding & Financial Promotions
Hybrid-commercial payment and e-money institutions that combine payment services with other, non-payment business lines must constitute a single ring-fenced asset pool -- the patrimonio destinato under Art.114-terdecies TUB -- dedicated exclusively to payment services and e-money issuance. The regime governs customer-fund protection design for any non-bank PI o
Conduct, Safeguarding & Promotions
The live W1b item is the finalised FSA conduct regime for the new electronic-payment-instrument/crypto intermediary category. These rules, effective 1 June 2026, give the category explicit registration, user-disclosure, explanation obligations, prohibited-conduct and recordkeeping requirements, shaping distribution economics for USDC/JPYC handlers ahead of implementation
Conduct, Safeguarding & Financial Promotions
Safeguarding of customer funds in Kenya runs through a mandatory bank-trust model. Non-bank PSPs must establish a trust with a CBK-licensed bank to hold customer and e-money funds, supported by a trust deed required under the NPS Act. This determines where the float sits and the insolvency-remoteness of customer funds for Kenyan e-money issuers. Conduct is laye
Conduct, Safeguarding & Financial Promotions
The National Bank of Cambodia mandates a standardised complaint-resolution mechanism via its Prakas on Resolution of Consumer Complaints, applicable uniformly across banking, payment and financial institutions. Cambodia's 2019 Law on Electronic Commerce shifts liability to the institution once a customer has notified it that an electronic payment instrument was
Conduct, Safeguarding & Promotions
The live W1b item is Korea's prepaid safeguarding rule. Effective 15 September 2024, prepayment service providers must separately manage at least 100% of customers' advance payments via trust or payment-guarantee insurance, invested only in safe assets — Korea Treasury and local-government bonds, bank or Korea Post deposits — with refund guaranteed on issuer bankruptcy.
Conduct, Safeguarding & Financial Promotions
Kazakhstan's conduct regulation is being rebuilt around the now-in-force New Banking Law. The law introduces a behavioural-supervision regime that shifts bank oversight away from a purely financial-metrics focus toward fair treatment of clients, and it establishes a two-step complaint process escalating to a Unified Financial Ombudsman. Because the parent law i
Conduct, Safeguarding & Promotions
BOL's Decree on Financial Consumer Protection was updated in an unofficial translation uploaded in January 2026. The update mandates that financial service providers safeguard consumer passwords and report significant data leaks to BOL's financial customer protection supervisory unit. This January 2026 upload republishes and updates the 2020 Decree 225/GOV translation ra
Conduct, Safeguarding & Financial Promotions
The safeguarding question in Brazil turns on how customer balances are held and protected, and it carries the non-bank PI/EMI distinction directly. The BCB permits payment institutions to hold customer balances in prepaid payment accounts, with PI settlement accounts funded at the BCB and costless standing facilities. However, full statutory asset-segregation r
Conduct, Safeguarding & Promotions
Liechtenstein's conduct regime for payment and e-money institutions centres on a mandatory safeguarding duty: PIs and EMIs must adequately safeguard client funds received directly or indirectly, and must notify the FMA in advance of any material change to their safeguarding arrangements. This obligation, embedded in the ZDG/EGG framework, gives supervised institutions a
Conduct, Safeguarding & Promotions
Safeguarding is the live conduct theme for Lithuania's non-bank EMIs and PIs, and it is the principal customer-fund-protection backstop in a sector with no FSCS-equivalent deposit guarantee. Under the Bank of Lithuania's framework, EMIs and PIs must safeguard client funds by one of three routes: segregation in a separate account at a credit institution in Lithuania, anot
Conduct, Safeguarding & Promotions
The live W1b item is CSSF Circular 26/906, published 20 January 2026 and effective 30 June 2026, which consolidates safeguarding into a dedicated chapter 8 with daily reconciliations, strict segregation of client funds, and a mandatory management-body member responsible for safeguarding oversight, alongside a three-lines-of-defence governance model and two authorised man
Conduct, Safeguarding & Financial Promotions
Conduct and consumer protection for Moroccan payments rests on Law 103-12 together with consumer-protection Law 31-08, enforced by Bank Al-Maghrib through transparency, complaint-handling and banking mediation. Law 31-08 grants an 8-day credit-withdrawal right. A primary BAM source anchors the regime. Critically for non-bank operators, customer funds at payment
Conduct, Safeguarding & Promotions
Myanmar's mobile financial service providers must safeguard customer float through segregated trust or deposit accounts held at partner commercial banks, reconciled daily by 4pm local time, with a duty to replenish the account if the liquidity receivable falls short. That formal safeguarding regime sits alongside a starkly different conduct track: junta authorities have
Conduct, Safeguarding & Promotions
Malta's safeguarding regime is anchored in the Financial Institutions Act (Cap. 376), the FIA (Safeguarding of Funds) Regulations (S.L. 376.04) and MFSA Financial Institutions Rules administered under the Fintech Supervision Function. Each EMI must safeguard and segregate funds representing e-money issued and is liable for any shortfall under S.L. 376.04. This segregatio
Conduct, Safeguarding & Promotions
(Duplicate module guard — see primary W1b entry above; this slot retained for enum completeness.)
Outlook
See primary W1b Outlook.
Conduct, Safeguarding & Promotions
The live conduct-and-safeguarding story in Malaysia is the revised Policy Document on Electronic Money, effective 31 January 2025, which replaced the 2022-vintage PD and materially raised the bar for non-bank e-money issuers. Large-scheme issuers must now hold customer funds in a Trustee Act 1949 trust account maintained with a licensed institution; small-scheme issuers
Conduct, Safeguarding & Financial Promotions
Market conduct across Mozambique's credit institutions, financial companies and IMEs is directly supervised by Banco de Moçambique itself, under Notices issued pursuant to Law 20/2020 - Notice 8/GBM/2021 on contractual terms and transparency, and Notice 9/GBM/2020 on complaints handling. There is no separate conduct authority distinct from the prudential regula
Conduct, Safeguarding & Promotions
The Nigerian safeguarding mechanism for non-bank e-money rests on a combination of trust-account segregation and deposit-insurance-style cover. Under the CBN Mobile Money Services Framework (July 2021), MMO customer mobile-money balances are held in nominee accounts on behalf of customers under CBN Payments System Management Department conditions, and the total outstandi
Conduct, Safeguarding & Promotions
The live W1b item is safeguarding. PSD2/EMD2 safeguarding is implemented in the Wft via two mechanisms: segregation — a third-party-funds foundation outside the firm's creditors' reach, or since 2022 a quality account — or an insurance or comparable guarantee from an out-of-group insurer or bank, in either case keeping customer funds outside the bankruptcy estate. Safegu
Conduct, Safeguarding & Financial Promotions
Nepal's approach to customer-fund protection departs structurally from the segregation/trust-account model common in more developed payments markets. Rather than requiring licensed PSPs to ring-fence customer funds in a dedicated trust or segregated account, the regime requires PSPs to enter a formal settlement-bank agreement for clearing/settlement before comm
Conduct, Safeguarding & Promotions
Conduct in New Zealand is governed by the Financial Markets Conduct Act 2013 and the CoFI regime, which requires fair-conduct programmes for banks, insurers and licensed non-bank deposit takers. There is no EMI-style statutory safeguarding or segregation regime. Instead, PSPs and e-money providers typically hold customer funds on trust in a licensed-bank trust account, a
Conduct, Safeguarding & Promotions
SBP Rule 1-2026, issued 16 January 2026, updates customer-due-diligence, enhanced-due-diligence, transaction-monitoring and internal-control obligations for all SBP-supervised entities, revoking prior rules 10-2015, 1-2013, 8-2000 and 10-2000. Secondary commentary anticipates a period of narrower fintech-client onboarding while institutions absorb the new compliance requ
Conduct, Safeguarding & Financial Promotions
Safeguarding of e-money float in Peru is anchored in Ley 29985 art.6, which mandates that e-money issuers constitute fideicomisos (trusts) as the guarantee mechanism for the value of e-money issued, with SBS empowered to regulate alternative guarantee modalities; user data is separately protected under Ley 29733. This trust-based mechanism remains the core safe
Conduct, Safeguarding & Financial Promotions
The core conduct anchor is the Financial Products and Services Consumer Protection Act (RA 11765), under which the BSP is empowered to protect the public against unfair, unconscionable or deceptive practices by supervised institutions, and every BSFI must maintain a Consumer Assistance Management System (CAMS). This is the FCPA-equivalent regime for the Philipp
Conduct, Safeguarding & Financial Promotions
Customer funds collected against e-money issuance in Pakistan must be placed into a segregated Trust Account with a licensed bank, held distinct from the EMI's own funds, under the EMI Regulations administered by the State Bank of Pakistan. This mechanism is the core customer-fund-protection architecture for the non-bank e-money sector and applies uniformly acr
Conduct, Safeguarding & Promotions
The conduct and safeguarding regime sits under the UUP. KIP applicants must evidence safeguarding accounts holding segregated client funds, risk-management and internal-control systems, civil-liability insurance or a bank guarantee for PIS provision, and SCA / secure open-communication compliance. The safeguarding mechanism is segregation: segregated safeguarding account
Conduct, Safeguarding & Promotions
Portugal's payment institutions and e-money institutions safeguard client funds under the PSD2 Article 10 regime, which permits either the Segregation Method or the Insurance Method. Under the Segregation Method, safeguarded funds must be held in a separate account with an authorised credit institution, or invested in secure liquid assets, by close of the following busin
Conduct, Safeguarding & Promotions
The conduct layer carries the live safeguarding and BNPL items, both bearing on the non-bank PI/EMI distinction. Non-bank licensees issuing e-money or carrying on merchant acquisition must perform an independent audit of the clients' money (escrow) account every six months and submit the report to QCB. The mechanism is segregation: a segregated clients' money (escrow) ac
Conduct, Safeguarding & Financial Promotions
Safeguarding and the EMI capital floor anchor the conduct-and-safeguarding picture for non-bank issuers. Romanian electronic money institutions must be authorised by the NBR with initial capital of not less than EUR 350,000 and are entered in the NBR Electronic Money Institutions Registry; credit institutions issuing e-money need no separate authorisation. This
Conduct, Safeguarding & Promotions
The NBS Decision on Governance, Internal Controls and Safeguarding mandates safeguarding of payment-service-user and e-money-holder funds by PIs and EMIs, sitting alongside a separate Decision on Capital and Capital Adequacy of PIs/EMIs. This conduct regime for non-bank payment providers is distinct from, but complementary to, the licensing track addressed in Licensing,
Conduct, Safeguarding & Financial Promotions
The Bank of Russia's Service for Consumer Protection and Financial Inclusion conducts both reactive, complaint-driven and proactive supervision of unfair market practices, backed by inspection and supervisory-response powers. The Bank of Russia is developing a bill to raise fines on credit institutions for consumer-rights violations, proposed at 0.1%-1% of an i
Conduct, Safeguarding & Promotions
The operative safeguarding mechanism for non-bank issuers is trust-account segregation. A non-BNR-supervised institution issuing e-money must hold a trust account at a licensed Rwandan commercial bank whose terms prevent the PSP from accessing those funds for non-payment operations, ensuring each customer's funds are always traceable and segregated. This is the customer-
Conduct, Safeguarding & Financial Promotions
The conduct and safeguarding layer in Saudi Arabia is codified through the Implementing Regulation's consumer-protection and e-money redemption provisions. EMIs must issue and redeem electronic money at par value, and activities requiring a pooled customer-funds account fall within the defined scope of payment services under Article 5-1, requiring a SAMA licenc
Conduct, Safeguarding & Financial Promotions
The full ban on credit transactions in gambling entered into force on 1 April 2026, applying across all forms of gambling in Sweden and now enforced jointly by Spelinspektionen and Finansinspektionen; compliance audits of licensed gambling operators began in Q2 2026. This is a correction to baseline research, which had characterised the ban as a measure that "w
Conduct, Safeguarding & Promotions
The live W1b items for Singapore are customer-fund safeguarding and the strengthening of conduct duties on e-payment providers. On safeguarding, Major Payment Institution licensees must safeguard customer monies via a bank or prescribed-FI undertaking or guarantee, a deposit in a trust account, or another MAS-prescribed safeguarding method, plus prescribed base capital a
Conduct, Safeguarding & Financial Promotions
Bank of Thailand minimum operating requirements for payment providers include good governance, risk management, consumer protection, security standards, business continuity planning and KYC policies, with the stated aim of protecting retail customers; these are supplemented by the Consumer Protection Act, the Electronic Transactions Act and the PDPA. Conduct an
Conduct, Safeguarding & Financial Promotions
Tunisia's conduct and safeguarding regime for payment institutions is built primarily on BCT Circular 2018-16. The circular tiers payment accounts by identification level: Level 1 accounts, opened under lightened identification, are capped at a 500 dinar balance and 250 dinar daily outflow; Level 3 accounts, requiring full identification and physical presence,
Conduct, Safeguarding & Promotions
Türkiye's safeguarding regime for non-bank EMIs rests on bank-held blocked segregation. E-money issuers must transfer funds received for e-money issuance into a separate bank account at Law No. 5411 banks, with the holding bank blocking those amounts during the term of use, thereby segregating customer funds from institution assets. This is a segregation mechanism rather
Conduct, Safeguarding & Financial Promotions
Funds stored in e-payment accounts must be deposited into a dedicated bank-provided escrow account under the E-Payment Act, legally protected from misappropriation and safe even upon provider insolvency.
The FSC has also taken direct enforcement action against e-payment providers over insufficient surety bonds and neglected anti-money-laundering reporting prot
Conduct, Safeguarding & Promotions
The safeguarding architecture for non-bank e-money issuers is distinctive. Non-bank e-money issuers must safeguard customer funds through a mandatory separate legal entity (trust) and a trust account under the Payment System (Electronic Money) Regulations 2015. This trust-based model diverges from the UK and EU segregation approaches and raises the structural cost of e-m
Conduct, Safeguarding & Promotions
The NBU's Office for Financial Services Consumer Rights Protection made Ukraine the 120th country worldwide to protect financial-services consumer rights under a 2019 law, with the NBU itself the 98th central bank to hold this function. A broader payment-accounts safeguarding regime remains at concept stage: the NBU's forthcoming legal framework is expected to include ne
Conduct, Safeguarding & Promotions
E-money issuers in Uganda must hold 100% of issued electronic money in a trust account, if non-bank, or a special account, if a licensed financial institution, in unencumbered liquid assets that are withdrawable on demand. Conduct is governed by the National Payment Systems (Consumer Protection) Regulations, 2022, gazetted 9 September 2022, which Bank of Uganda is report
Conduct, Safeguarding & Financial Promotions
The US payments safeguarding mechanism operates through state Money Transmitter Licence 'permissible investments' — qualifying liquid assets equal to outstanding payment obligations — backed by surety bonds and minimum net worth, with no unified federal CASS or PSD2-equivalent safeguarding regime. These permissible investments function as the US customer-fund-p
Conduct, Safeguarding & Financial Promotions
Safeguarding in Alaska runs through trust law rather than a bespoke conduct rulebook. Statutory trust (AS 06.55.501 et seq.) requires permissible investments, including virtual currency, to be held pro rata for outstanding customer obligations, and rehypothecation of consumer-held virtual currency is expressly barred -- a strict, no-lending-of-client-assets sta
Conduct, Safeguarding & Promotions
Alabama's conduct regime for money transmitters gained its first virtual-currency-specific layer this cycle: HB303, the Cryptocurrency Kiosk Fraud Prevention Act, was enacted and signed by Governor Kay Ivey and takes effect October 1, 2026, superseding earlier tracking that had the bill pending in the Senate. The enacted law requires kiosk operators to issue transaction
Conduct, Safeguarding & Promotions
Arkansas's safeguarding model for customer funds rests on the Money Services Act's Permissible Investments article, which requires licensees to hold investments matching outstanding transmission and stored-value obligations, rather than segregating customer funds in a discrete trust account, and is backstopped by the Article 6 examination and investigation authority unde
Conduct, Safeguarding & Financial Promotions
Arizona's safeguarding regime, codified through SB1580, requires authorized delegates of money transmitter licensees to hold transmitted funds, net of fees, in trust for the licensee; commingled funds are deemed held in trust to the extent of transmission proceeds. Licensees must additionally file a GAAP-audited annual financial statement within 90 days of fisc
Conduct, Safeguarding & Promotions
California's conduct regime rests on the California Consumer Financial Protection Law (CCFPL), the foundational statute creating the modern DFPI, which grants broad authority to police unlawful, unfair, deceptive or abusive acts or practices (UDAAP) across financial-service providers, including previously unregulated fintechs. The CCFPL functions as California's de facto
Conduct, Safeguarding & Promotions
DC's approach to safeguarding customer funds diverges from the segregation-of-funds trust model used elsewhere: DC money transmitters satisfy financial-responsibility and safeguarding obligations via a surety bond, with a minimum of $50,000 scaling to a maximum of $250,000, filed through NMLS as part of DISB licensure, rather than through a trust-based segregation regime
Conduct, Safeguarding & Promotions
Safeguarding for Delaware money transmitters runs through mandatory surety bonds or irrevocable letters of credit under §2309, paired with a statutory duty to furnish serially-numbered customer receipts under §2313. SB18 layers standardized receipts and new refund and timeliness protections onto this framework, nationalizing standards for money transmitters such as PayPa
Conduct, Safeguarding & Financial Promotions
Under s.560.1105, F.S., licensees and authorised vendors must retain compliance-relevant books, accounts, documents and files for five years and produce records to the Office of Financial Regulation within three business days of a written request; this recordkeeping baseline is sourced to a 2021 statute snapshot and has not been independently confirmed current
Conduct, Safeguarding & Financial Promotions
Georgia's safeguarding model rests on a clearing-account mechanism rather than a trust or segregation-of-funds requirement typical of EMI regimes: licensees must maintain collected funds on deposit in a clearing account sufficient to transmit money and pay outstanding transactions, with quarterly reporting of outstandings due within 45 days of quarter-end, oper
Conduct, Safeguarding & Promotions
HRS 489D-7 and 489D-8 impose Hawaii's core safeguarding mechanism for nonbank money transmitters: licensees must maintain a bond or other security device and hold permissible investments matched to outstanding payment-instrument obligations. The commissioner may waive certain requirements where posted security already exceeds outstanding volume, and a letter of credit is
Conduct, Safeguarding & Financial Promotions
Iowa has no dedicated EMI-style conduct regulator; the state's conduct backstop for payments runs through general consumer-protection law layered onto Chapter 533C's own conduct provisions. The Iowa Attorney General's Consumer Protection Division enforces the Iowa Consumer Fraud Act (Iowa Code 714.16) alongside Chapter 533C requirements covering timely transmis
Conduct, Safeguarding & Promotions
Idaho money transmitters must furnish a safeguarding security device of at least $10,000, increasing $5,000 per branch to a maximum of $500,000, running to the state for the benefit of claimants against the licensee under Idaho Code 26-2908. This is a bond/security-device model, not a UK/EU-style client-money trust or segregation regime -- a materially different consumer
Conduct, Safeguarding & Financial Promotions
Illinois' conduct and safeguarding framework has been substantially reinforced over the past two years. The Illinois Consumer Financial Protection Law, modeled on the federal CFPB-creating statute, grants IDFPR UDAAP-style enforcement authority over licensed and unlicensed financial-services providers, including payments and fintech entities, giving the regulat
Conduct, Safeguarding & Financial Promotions
Indiana's conduct and safeguarding layer has been reshaped by the Earned Wage Access Act (EWAA, HB1125), which requires most earned-wage-access providers to hold a DFI licence effective 2026-01-01; NMLS applications were accepted from 2025-10-01, with a grace period running to 2026-04-30. Enacted EWAA provisions, per bill-tracker records, set a surety-bond rang
Conduct, Safeguarding & Financial Promotions
Every KMTA licensee must at all times hold permissible investments with an aggregate market value not less than its aggregate outstanding payment liability in the United States - the Act's core consumer-fund safeguarding mechanism. SB 44 requires money transmitters and other covered financial institutions to comply with GLBA Safeguards Rule standards as in effe
Conduct, Safeguarding & Financial Promotions
Kentucky's safeguarding mechanism for money transmitters is trust treatment of commingled agent proceeds under KRS 286.11-037, backstopped by the Department of Financial Institutions' complaint, investigation, and licence-suspension powers under KRS 286.11-055. Republic Bank & Trust was the subject of an FDIC Amended Notice of Charges finding systemic third-par
Conduct, Safeguarding & Financial Promotions
Louisiana's fund-safeguarding baseline rests on statute rather than a bespoke safeguarding rulebook: money transmitters must transmit or return consumer funds within 10 business days of receipt under R.S. 6:1055, and R.S. 6:1052 assigns the trust-style proceeds of revoked licensees to the OFI commissioner. The Louisiana Unfair Trade Practices and Consumer Prote
Conduct, Safeguarding & Financial Promotions
Alongside the licensing overhaul, Massachusetts has installed a new safeguarding regime: money-transmitter licensees must hold permissible investments equal to 100% of outstanding transmission obligations, limited to cash and cash equivalents, CDs or senior debt of insured depositories, US or agency obligations, standby letters of credit, and the surety bond am
Conduct, Safeguarding & Financial Promotions
Maryland's core consumer-fund safeguarding mechanism for money transmitters is a surety bond rather than a trust or segregation model: a minimum $150,000 bond, scaling to $1,000,000 with transmission volume, stands in place of asset segregation. Conduct requirements tightened substantially this cycle. Senate Bill 94, signed April 28, 2026, bans tipping in earne
Conduct, Safeguarding & Financial Promotions
Michigan's current safeguarding model for non-bank money transmitters rests on a permissible-investments requirement — including ACH and credit-card receivables under DIFS Order No. 2018-003-CF, effective 2018-02-12 — backed by the mandatory surety bond rather than a statutory trust. DIFS holds confidentiality and examination powers over licensee information un
Conduct, Safeguarding & Financial Promotions
The 2026-session Data Security for Money Transmitters Act (HB1596), approved by the Governor on April 8, 2026, layers the state's first dedicated conduct and cybersecurity duties onto MTL licensees, requiring a written information-security program, risk assessments, a qualified-individual designation and breach notification to the Commissioner.
Companion kiosk
Conduct, Safeguarding & Financial Promotions
Montana's conduct and safeguarding regime for non-bank payment-adjacent activity operates through activity-specific bonding rather than a single unified code. Escrow licensees must post a $100,000 surety bond and debt-management licensees a $50,000 bond, with the Montana Unfair Trade Practices and Consumer Protection Act (MUTPCPA, Title 30 chapter 14) serving a
Conduct, Safeguarding & Financial Promotions
Safeguarding of customer funds for North Dakota money-transmitter licensees does not rely on pure trust-account segregation; instead, NDCC 13-09-04 requires licensees to maintain permissible investments with an aggregate market value not less than the aggregate face amount of outstanding payment instruments and stored value, functioning as the statutory backsto
Conduct, Safeguarding & Financial Promotions
Nebraska's safeguarding regime for nonbank money transmitters centres on LB474's surety-bond mechanism: a minimum $100,000 bond, scaling with liability, that gives NDBF authority to claim on the bond on customers' behalf, alongside codified 10-day refund-timing rules. On the conduct side, LB609 (the Controllable Electronic Record Fraud Prevention Act), effectiv
Conduct, Safeguarding & Financial Promotions
New Hampshire's prudential and safeguarding regime for money transmitters rests on three linked statutory pillars: net-worth maintenance (RSA 399-G:26), the surety bond (RSA 399-G:27), and permissible-investment maintenance (RSA 399-G:28-29), which together back outstanding transmission obligations. This combined net-worth-plus-bond-plus-permissible-investment
Conduct, Safeguarding & Promotions
Safeguarding of transmitted customer funds in New Jersey continues to rest on the surety-bond/letter-of-credit model established under N.J.S.A. 17:15C-8, rather than a segregation-of-funds requirement, and DOBI imposes no separate liability-insurance prerequisite on top of that bond. Conduct is policed primarily through the Consumer Fraud Act, and this cycle's dominant d
Conduct, Safeguarding & Promotions
Money transmitters safeguard customer funds via a surety bond payable to the State of Nevada, sized at the greater of a statutory minimum or 100% of average daily transmission liability up to a $500,000 cap, alongside restrictions on permissible investments such as excluding delegate receivables older than seven days. Trust companies, the digital-asset-custody route, ins
Conduct, Safeguarding & Promotions
Safeguarding for NY non-bank transmitters rests on Banking Law §651, which requires every licensee at all times to maintain permissible investments with a market value at least equal to the aggregate of all outstanding payment instruments and traveler's checks. This is a strict ongoing 100%-liability cover, not a one-time threshold, and is distinct from bank FDIC or depo
Conduct, Safeguarding & Financial Promotions
Customer-fund protection for Oklahoma money transmitters is not built on trust-account segregation, as in the EU/UK model, but on a mandatory surety-bond regime: electronic-means transmitters must maintain a minimum $200,000 security bond under 6 O.S. §1513(E), with required bonding scaling from $50,000 to $500,000 depending on transaction volume, plus per-dele
Conduct, Safeguarding & Promotions
Under ORS 717.225, Oregon requires MTL licensees to maintain a security device, a surety bond or equivalent running to the State of Oregon, capping aggregate claimant liability at the device's principal sum, a bond-based safeguarding model rather than a segregation or trust-account regime. Conduct and marketing fall under the general Oregon Unlawful Trade Practices Act,
Conduct, Safeguarding & Financial Promotions
Pennsylvania has no dedicated payments-conduct or safeguarding regulator comparable to the UK's CASS regime. Conduct oversight instead runs through the General-purpose Unfair Trade Practices and Consumer Protection Law (UTPCPL), with the Attorney General's Consumer Financial Protection Unit acting as the de facto state UDAAP analogue for both bank and non-bank
Conduct, Safeguarding & Financial Promotions
South Carolina money transmitters must maintain a surety bond of $50,000 plus $10,000 per additional office, capped at $250,000, and a net worth of at least $250,000. The state does not separately mandate a customer-fund segregation or trust model, leaving safeguarding resting on solvency-style capital requirements rather than fund segregation.
Pending Bill 45
Conduct, Safeguarding & Financial Promotions
South Dakota money transmitter licensees must maintain safeguarding via a statutory trust of permissible investments matching outstanding transmission obligations, plus a surety bond scaled $100,000-$500,000 based on average daily transmission liability per SB 58 (2024), with a 120-day statutory application review period. Separately, the Division of Banking man
Conduct, Safeguarding & Promotions
Safeguarding for Utah money transmitters rests on a minimum $50,000 surety bond rather than a UK-style statutory segregation regime, with DFI able to raise the bond requirement and, where a licensee is found unsafe or unsound, to compel it to deposit funds with an acceptable financial institution or to cap or prohibit further payment-instrument issuance. Conduct and prom
Conduct, Safeguarding & Financial Promotions
Vermont-licensed money transmitters have safeguarded customer funds through a statutory trust since July 1, 2024, when Act 110 §44 took effect. The trust holds permissible investments for the benefit of money-transmission-obligation holders, and trust assets are shielded from attachment by creditors except by the trust's own beneficiaries.
This statutory-trust
Conduct, Safeguarding & Financial Promotions
Each Washington money transmitter licensee must designate a Responsible Individual — a US citizen or lawfully authorised worker employed as a W-2 employee — who is accountable for state and federal compliance under WAC 208-690-014(2). Licensees are further bound by a statutory duty to transmit customer funds within ten business days of receipt and to refund all
Conduct, Safeguarding & Promotions
Wyoming's safeguarding requirements diverge by licence track. Money transmitter licensees must maintain permissible investments — cash, certificates of deposit, securities and US Treasuries — equal to outstanding obligations, and post a surety bond starting at a $10,000 minimum and scaling to $500,000 at 2.5x outstanding volume, alongside audited annual statements; no de
Conduct, Safeguarding & Promotions
Two conduct layers apply to Venezuelan payments providers, one bank-specific and one aimed at the ITFB fintech track. ITFBs authorised under SUDEBAN Resolution 001-21 must maintain a performance bond of no less than EUR 20,000 equivalent at the BCV rate and implement risk-management controls where using AI, analytics or cloud computing. Separately, SUDEBAN Resolution 063
Conduct, Safeguarding & Promotions
The conduct and safeguarding layer is now fully defined and applies principally to non-bank PI/EMI operators. E-wallet providers must safeguard customer funds through a 1:1 payment-assurance (escrow) account held at an associated bank, are prohibited from receiving cash directly from customers, and may accept top-ups only via deposit to the payment-assurance account, fro
Conduct, Safeguarding & Promotions
South Africa operates a Twin Peaks supervisory architecture established by the Financial Sector Regulation Act 2017: the SARB Prudential Authority is the prudential supervisor and the FSCA is the market-conduct authority, with section 107 of the FSR Act empowering joint standards. This split defines the conduct and customer-fund-protection obligations payment operators f
Signal sourced from the dedicated CASS-15 Safeguarding sub-strand of W1b where available; W1b (AML/CFT Supplemental — conduct & safeguarding passages) for remaining JIDs. Dedicated sub-strand coverage expands automatically as pipeline research roles run.