In August 2025, the FCA published its Policy Statement on the new safeguarding rules for payment services and e-money firms, with an implementation deadline of May 2026. These new rules will broadly expect payment and e-money firms to undertake annual audits, implement monthly reporting and daily checks, and ensure they have appropriate plans in place for firm failure, including a wind-down plan.

How we can help

PSR / EMI firms will need to comply with these safeguarding rules to address the inherent risk of insolvency in the event of regulatory breaches, resulting in funds not being safeguarded. Firms will be required to ensure that they have a wind-down plan in place that addresses the following key areas:

  • The key triggers for both solvent and insolvent wind-down;
  • Identifying all third parties the firm deals with;
  • Detailed explanation on how repatriation of funds would be achieved so that a third party is able to understand;
  • Have prepared detailed cashflow projections to reflect the wind-down and further stress tested  the cash flow plan;
  • Have an overview of IT infrastructure and cyber security controls; and
  • Proper assessment of non-financial resources.

Senior specialists to support you

Our multi-disciplinary team of senior specialists blends a strong background in financial advisory, restructuring, special situations and regulatory expertise to deliver actionable results. We complement this with unrivalled experience in working with the key regulatory stakeholders in respect of regulated businesses.

Here to help

If you would like more information, please contact our FS specialists: 

 

Dina Devalia
Managing Director
T: +44 (0)20 3872 8342
M: +44 (0)7557 419 361
E: dina.devalia@quantuma.com

 

 

Brian Burke
Managing Director
T: +44 (0)20 3856 6720
M: +44 (0)7464 545 265
E: brian.burke@quantuma.com

Article

purple & black swirl with light
05 March 2024
FCA reminds Financial Services firms of the importance of preparing a wind-down plan
Author: Paula Fagan, Marketing Manager

As part of its latest key updates, the Financial Conduct Authority (FCA) has published guidance for Financial Services (FS) firms on preparing a wind-down plan. The purpose of a wind-down plan is to enable a FS firm to cease its regulated activities and exit the market in an orderly manner, if its business is no longer viable. The FCA states that it: ‘expects firms to consider the scenarios leading to financial stress, explore recovery options and, as a last resort, wind-down their business’.

Article

purple-hexagons-abstract
12 February 2024
Dangers of complacency: Are your Client Asset Sourcebook (CASS) controls really as watertight as they should be?
How financial services firms can gain confidence in CASS compliance.

If your business goes down, failure to segregate clients’ assets could leave clients/consumers seriously out of pocket. But poor systems, oversight and control, combined with a lack of proper documentation, mean that many financial services (FS) firms are falling short of their CASS obligations and leaving their senior management team at risk of severe regulatory sanctions.

Dina Devalia looks at why CASS should be front and centre of the boardroom agenda and how to gain real confidence that your client money safeguards are fit for purpose.

Article

purple abstract shell waves
06 December 2023
Prepared for the worst: How to turn wind-down planning into a source of strength
Savvy planning tips for financial services firms.

The Financial Conduct Authority (FCA) is turning up the spotlight on what it sees as “widespread weakness in wind-down planning”. If your wind down planning (WDP) fails to meet the FCA’s expectations, your firm could face an increase in regulatory scrutiny on capital and operational controls. But as Dina Devalia explains, effective wind-down planning isn’t just a compliance exercise. It’s also a good way to test the viability of your operations. So how can you get your wind-down planning up to the mark?