Money Service Businesses

Our clients include Money Service Businesses who came under regulatory supervision for the first time from 1 November 2009 when the Payment Services Regulations (‘2009’) were implemented in the UK.

Firms which provide money transfer services after that date had to be authorised or registered with the FSA and had to comply with Conduct of Business procedures and complaints handling procedures from 1 November 2009.

Gem Compliance Consulting was one of the first compliance consultants to work with Money Service Businesses. In May 2009, before the new regulations came into force, we made a presentation to UKMTA members outlining the implications of FSA supervision.
Since then we have worked successfully with a number of Money Service Businesses advising them on
FCA authorisation or registration applications and project managing the overall process to ensure that key deadlines for application submission are met.

It is important that firms get their application process completed correctly first time. Incomplete or inaccurate submissions are likely to create a poor first impression. We have extensive experience of the application process and a good understanding of what the regulator is looking for from Money Service Businesses in terms of a regulatory business plan, systems and controls, financial information and risk management. This also includes documenting an appropriate compliance manual for firms to use once authorised or registered.

FCA application support also includes guidance on:

  • conduct of business requirements
  • capital adequacy
  • complaints handling procedures
  • treating customers fairly
For any firms that continue to transition, revised conduct of business and complaints handling procedures should already have been implemented from 1 November 2009. As part of this support, we can review the firm’s existing procedures prior to application and if appropriate discuss any gaps which may need to be addressed and identify appropriate solutions to do so.

On an ongoing basis, we can provide ad hoc technical support on FCA supervision including completing annual returns, and complaints handling. Support can also include an annual healthcheck on compliance with FCA requirements or more frequent ongoing monitoring covering higher risks of FCA compliance.
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