Controls examination
Customer-fund safeguarding review
A focused review of how customer electronic money is segregated, confirmed, and reconciled — the chapter regulators read first when the rest of the file is noisy.
Safeguarding is where application files most often look finished and are not. A trust or designated account letter is not the same as a working reconciliation. We examine whether the legal form of the account, the daily posting logic, and the month-end customer liability can be shown to match.
The review covers account designation, eligible institutions, the treatment of in-flight merchant payouts, chargebacks, promotional credits, and dormant balances. We ask the bank or trustee for confirmations in a form that can sit in the application pack, and we test at least one month-end cut-off against the wallet ledger.
If the wallet is not yet live, we examine the proposed posting rules and the draft bank mandate, then flag the gaps that will be obvious the first time a safeguarding return is prepared.