Authorised payment institutions and EMIs run safeguarding, PSRs and EMRs monitoring, APP-fraud controls and financial-promotion approvals from one platform — with the evidence trail the payments regime demands.
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E5 dedicated CMP chapter
Relevant funds, reconciled and evidenced
Maker-checker approval built in
Safeguarding, fraud, promotions, financial crime — the FCA doesn’t ask whether customer money is protected. It asks you to prove it, and the burden of proof sits with the firm.
Safeguarding is the FCA’s flagship concern for the payments sector. “Relevant funds are protected” isn’t enough — the record has to show which funds, in which accounts, reconciled and evidenced.
A promotion goes out; the approval lives in someone’s inbox. When the FCA asks who signed it off — and when — the trail has to exist.
Mandatory reimbursement turned APP fraud from a customer-service problem into a regulatory one. Claims, decisions and reimbursements need a controlled, evidenced process — not an inbox.
CASS 10A expects your safeguarding resolution pack to be retrievable within 48 hours. If assembling yours means a week of archaeology across drives and inboxes, it isn’t a pack — it’s a liability.
Payment and e-money firms carry bank-grade financial-crime expectations — CDD, transaction monitoring, sanctions screening, SARs — usually on a fraction of a bank’s headcount.
Safeguarding reform, APP-fraud rules and e-money guidance land weekly across 13 UK regulators. Missing the one that rewrites your obligations is how firms fall behind.
Named chapters, registers, engines and filters for firms whose obligations live in the PSRs 2017, the EMRs 2011 and CASS 15.
E5 Payment Services & E-Money Institutions puts 20 sector-specific checks into your monitoring plan — safeguarding under regulations 23 and 24, conduct and complaints under regulations 98–101, the EMRs 2011, BCOBS on the deposit side and the PSR’s APP-fraud regime. Backed by a deep-dive chapter on fraud controls (B9). All inside the 1,139-template library.
A register variant built for the payments regime: every promotion logged, put through maker-checker approval before it runs, and closed with a timestamped audit trail — with a BCOBS variant for deposit-side communications.
A dedicated Payment Services attestation form tests your arrangements directly against the Handbook — a guided question set, evidence attached, sign-off recorded.
The relevant-funds calculation under CASS 15.8, safeguarding reconciliations and acknowledgement-letter tracking — plus a CASS 10A resolution pack you could hand over within 48 hours. Policy Studio’s three CASS policies cover the safeguarding documentation alongside.
Regulatory Intelligence carries a dedicated Payments sector filter, keyword-mapped to the PSRs, PSD2, e-money, safeguarding, APP fraud and Open Banking — and Otto scores each item’s relevance to your firm across the 13-regulator feed.
The B9 fraud chapter monitors your fraud controls — APP-fraud reimbursement included — while the Financial Crime module carries the full AML and sanctions stack: CDD registers, transaction monitoring, sanctions screening and SAR routes, each with its evidence trail.
The E5 payments chapter lands in your programme complete — checks, owners, cadences and regulatory references — with the registers and attestations payment and e-money firms run alongside.
E5 Payment Services & E-Money Institutions — anchored to the PSRs 2017, the EMRs 2011, BCOBS and the PSR’s APP-fraud regime.
74 regulation-anchored categories, including a deep-dive chapter on fraud controls (B9).
The financial-promotions register in its Payment Services variant — maker-checker approval before anything runs, every decision timestamped.
The Payment Services attestation form with guidance in-form and sign-off recorded — declarations you can produce, not reconstruct.
The head-of-compliance landing surface. Live KPI tiles for open, closed and overdue tasks, completion and approval rates, an overall Health Score, RAG summary and monthly trends — every tile a one-click drill-down to the records underneath.
1,139 expert-built monitoring checks across 74 regulation-anchored categories — including the E5 payments chapter and deep-dive chapters on financial promotions and fraud controls. Each template ships with a regulatory reference chain and plain-English guidance that pre-populates in-form.
Every formal declaration, completed and signed off in-platform. Attestation forms including the specialist Payment Services form, with a maker-checker approval workflow — the form can’t be submitted until every obligation is signed off.
Every event your firm has to record, in one tracker. Financial promotions in their Payment Services variant, complaints, breaches, gifts & entertainment and conflicts — status chips, named owners, due dates and the same maker-checker approval workflow throughout.
Relevant funds run on a dedicated safeguarding engine — the CASS 15.8 calculation, reconciliations, acknowledgement letters and a CASS 10A resolution pack ready for retrieval.
Internal and external reconciliations of relevant funds against your safeguarding accounts — the records a safeguarding audit is built on.
The relevant-funds calculation under CASS 15.8, logged with discrepancies and shortfalls flagged and tracked to resolution.
Safeguarding bank accounts tracked with acknowledgement-letter status and bank concentration — every account named and evidenced.
The CASS 10A resolution pack mapped and retrievable, with a readiness gauge and a one-click master document.
The whole safeguarding position on one screen. A Client Assets Health score with a pillar-by-pillar profile, and live tiles for bank concentration, the relevant-funds calculation, 48-hour resolution-pack readiness and a 12-month breach heat-map — every safeguarding obligation, RAG-rated, at a glance.
Internal and external reconciliation engines for relevant funds. Log each safeguarding reconciliation, flag discrepancies and shortfalls, and track them to resolution — the daily discipline the safeguarding regime expects, kept current and exportable.
Every safeguarding record as a structured register — safeguarding bank accounts with acknowledgement-letter status and bank concentration, mandates and the wider client-asset registers. The evidence an FCA visit or a safeguarding audit asks for, already assembled.
The CASS 10A resolution pack, mapped and retrievable. Every required document and record flagged for 48-hour or immediate retrieval, with a readiness gauge and a one-click master document an insolvency practitioner could act on — the pack the FCA expects you to produce within 48 hours.
Payment and e-money firms carry bank-grade financial-crime expectations — fraud controls, transaction monitoring, sanctions screening — alongside the APP-fraud reimbursement regime. One module holds the lot.
The B9 fraud chapter puts your fraud framework — APP-fraud reimbursement included — on a scheduled, owned and evidenced monitoring cycle.
Your rule set, thresholds and tuning cadence documented, with an alert-investigation register and a red-flag and typology watchlist.
Your screening programme documented — lists, thresholds, cadence — with a hit log, frozen-assets and OFSI licence registers.
An MLRO report suite including a REP-CRIM data return — the numbers the regulator asks for, drawn from your live records.
The MLRO’s morning glance. Financial Crime Health score, live operations across every regime, KPIs, the MLRO calendar and review SLAs — the whole function on one screen, every weakness one click from the work that fixes it.
The transaction-monitoring workspace: your rule set, thresholds and documented tuning cadence in one place, an alert-investigation register with dispositions, and a red-flag and typology watchlist for spotting what name-screening alone misses — each with evidence attached.
The sanctions workspace: your screening programme — lists, thresholds, cadence — documented in one place, a hit log with dispositions, frozen-assets and OFSI licence registers, and a breach log with the reporting route named from the start.
Otto is the platform’s built-in compliance advisor, grounded in 150+ expert-authored documents. She reads your live monitoring, safeguarding and financial-crime records — not a generic handbook summary — and drafts the reports the regulator expects to see.
Your year’s monitoring drafted from live data, citing CASS among its 13 regulatory anchors — safeguarding, fraud and conduct coverage, findings and remediation, section by section.
A CASS oversight report grounded in your live safeguarding records — reconciliations, discrepancies and resolution-pack readiness, drafted before the auditor asks.
The MLRO annual drafted from your live financial-crime records, with a REP-CRIM data return drawn from the same evidence.
Payment and e-money firms serving retail customers are in scope — Otto drafts the 13-section annual board report from your live Duty evidence.
AI drafts, humans decide — nothing is auto-submitted, and every fact traces to your live firm data.
Three ways to run payments compliance. Only one produces evidence the FCA can inspect — on the day they ask for it.
What a payments-firm founder or an e-money MLRO wants to know about platform-grade safeguarding compliance.
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