E-money

The greater flexibility offered by e-money authorisation (compared with Payment Institution authorisation), particularly in terms of the ability to hold customer funds on an ongoing basis, means that it has become an increasingly popular option for firms.

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Our expertise

The question of what is and isn’t e-money within a particular business model and whether the firm is also providing unrelated payment services, can be difficult to understand and requires detailed analysis, particularly as this can affect the safeguarding arrangements and “own funds” requirement. Specialist analysis and support can help firms satisfy the regulator’s expectations.

In addition, the FCA is becoming ever more interested and assertive in checking whether, and how, e-money firms are complying with their requirements. This is especially the case in terms of safeguarding, where all E-Money Institutions (EMI), authorised or small, are required to have an annual safeguarding audit. Our team have done many such audits and have a good view of both industry standards and the FCA’s expectations. We can also provide specialist support in terms of prudential requirements, liquidity testing and wind-down planning, all of which are high on the FCA’s priority list.

Whether your firm is thinking of seeking e-money authorisation, want to be able to prove to the FCA how it is complying, or is dealing with an FCA information request, speak to our expert team to help you to keep the regulator happy.

DOWNLOAD OUR FCA Licence Options for e-money Firms FACTSHEET

FCA authorisations and application services

FCA Authorisation

We have managed over 1,500 successful FCA applications across all sectors and frequently interact with the FCA to keep our understanding of its requirements fresh and up to date.

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Brexit and TPR

If you are a firm from within the European Economic Area (EEA) and are looking to continue or start offering financial services in the UK, we can help you to get authorised and regulated by the FCA.

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FCA Sandbox

The FCA Sandbox is open to authorised firms, unauthorised firms that require authorisation and technology businesses that are looking to deliver innovation in the UK financial services market. Cosegic can help firms prepare their application to enter the FCA Sandbox and help them navigate through to successful authorisation.

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Variation of Permission

If you are an authorised firm looking to change your regulated activities, start a new business line or add new product/client types to your business line, we can support you with your variation of permission (VOP) application.

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Change in Control

If you are looking to acquire or increase control of a regulated firm you must send a notification to the FCA for a Change in Control (CiC) and have prior approval from the FCA before the transaction can go through. We can help you notify the FCA of the change and ensure that the CiC goes smoothly.

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Agents and Distributors

We can help payment services and e-money agents meet the compliance requirements of their principals as well as help to ensure that principal firms are hosting a compliant network.

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Ongoing compliance support and regulatory projects

Regulatory Reporting

Regulatory reporting is the main regular communication the FCA has with most firms. Mistakes in regulatory reporting can lead the FCA to conclude that the firm’s controls are not at an appropriate level, and lead to further investigation. We can help ensure that firms get it right the first time.

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Consumer Duty

A wide range of services options to support all firms with the implementation of the new Consumer Duty.

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Capital and Liquidity Adequacy

The FCA is looking very closely at the financial stability of firms which it regulates. We help firms to monitor that they are meeting their regulatory capital requirements on an ongoing basis, and that their liquidity testing meets the FCA’s expectations.

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Wind-down planning

The FCA has made it clear that all regulated firms need to understand how they would wind-down their business in practice. We have assisted numerous firms with theirs, so understand the scope and level of detail the FCA expects.

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Compliance Healthcheck

Our Compliance Healthcheck gives you comfort and peace of mind that you have appropriate compliance arrangements in place.

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Training

Ensuring your management and staff receive appropriate compliance training is a requirement of the FCA’s regulations. We offer two options, online training courses using our PortAll software and bespoke classroom training and workshops

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Financial Crime

Under UK legislation, relevant firms must be able to demonstrate that they have robust governance, effective risk procedures and adequate internal control mechanisms to manage their financial crime risk. We help a broad range of firms across all financial sectors, with a special emphasis on those organisations for whom financial crime is especially complex and demanding.

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Ongoing Compliance Support

Cosegic support hundreds of firms with their ongoing compliance requirements, be it through regular compliance monitoring, online and classroom training, compliance assurance reviews or carrying out remediation required to meet regulatory obligations.

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Safeguarding Audits

Safeguarding is the primary customer protection measure for payment services and e-money firms, hence it is one of the FCA’s main areas of focus for our sector. As one of the most knowledgeable and respected Payment Services regulatory compliance consultancies, we have the qualifications and experience to undertake the required independent safeguarding audit.

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Payments Compliance factsheet

Payment services firms need to be aware of the compliance obligations of the Payment Services Regulations. To help them understand their obligations, Cosegic has produced this useful checklist setting out what you must do, what the Financial Conduct Authority (FCA) expect and the reporting and notification obligations that apply to some firms.

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Ongoing support services

We offer different retainer service options to help Payment Institutions meet the Payment Services Regulations and associated regulatory obligations, as well as being there to deal with unwanted issues such as incident reporting, should they happen.

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Why choose Cosegic?

Our 360 degree perspective of regulatory affairs

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Our 360 degree perspective of regulatory affairs

Our wide range of financial sector experts come together on a regular basis to discuss their interactions with the FCA and the regulatory trends that they are seeing, providing us with a more informed understanding of the FCA than our competitors.

Direct, proportionate advice

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Direct, proportionate advice

Our unique perspective means we really do have our fingers on the pulse of regulation, which helps us to ensure that the advice we offer is practical, helpful and directly proportionate to our clients’ needs.

Our understanding of the role of compliance in firms

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Our understanding of the role of compliance in firms

We have watched the evolution of compliance over the past twenty years and understand that compliance must now become a core part of how financial services carry out their businesses in order for them to be successful.

Compliance confidence for visionary growth

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Compliance confidence for visionary growth

In recognising this, our services have been built in a way that can help you navigate regulation ensuring you will keep your vision and objectives intact. Our breadth of experience allows us to balance your business objectives with your compliance requirements.

We're experts in our field

Meet James Borley, Managing Director of our Payment Services practice. James is a highly qualified financial services expert and a familiar name to many in the payments and e-money community. James leads our Payment Services Practice and provides technical support to our clients, specialising in payment services regulation and new firm authorisations. James represents Compliancy Services as a member of CryptoUK; The Association of Foreign Exchange and Payment Companies (AFEP); and The Association of Professional Compliance Consultants (APCC), where he chairs the FCA Authorisations Working Group and co-chairs the Crypto Working Group.

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