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New safeguarding regime presents high compliance burden

Man doing a contactless payment with smartphone application in a grocery store.
Photo: Artur Debat/Getty Images

Chris Glennie | CMS, Sam Robinson | CMS, Mike Ringer | CMS, James Dickie | CMS+2

7 min read
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Payments and e-money firms impacted by codification of guidance and new requirements including the imposition of a statutory trust.

On September 25, 2024, the FCA published CP24/20 setting out its proposed changes to the safeguarding regime for payments and e-money firms. The consultation closes to comments in December.

The changes are likely to present a high compliance burden for many firms. While many of the requirements are examples of the

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