Arthur Temlett

Limits on what they may do

• Assets requirement

  1) The Firm must not, without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of any of its assets, and any funds it holds for, or to the order of, its customers or investors (whether in the United Kingdom or elsewhere), whether held by the Firm as at the date of the imposition of the Requirements or acquired thereafter. 2) Sub-paragraph (1) constitutes an assets requirement within the meaning of section 55P(4)(a) of the Act.

• Notification requirement

  3) The Firm must, by 17:00 on 24 January 2024, notify any investor, or any person with whom the Firm has dealt with as a customer, or other relevant person directly affected by the Requirements, of the terms and effect of the Requirements. The wording of this communication and the method of delivery must be agreed in advance with the Authority. 4) Once the notifications referred to in paragraph (3) above has been made, within 24 hours, the Firm must supply to the Authority:  a) Copies of the template notifications sent to all recipients;   b) A list of all parties to whom notifications have been sent; and   c) Confirmation that, to the best of its knowledge, the Firm has sent the specified notifications to all relevant parties.  5) The Firm must provide to the Authority, by no later than 12 noon each Friday until such time as is notified otherwise in writing by the Authority (starting from the first Friday after the imposition of the Requirements), account statements for all of the Firm’s bank accounts, payment accounts, investment accounts and e-money accounts, whether held in the UK or outside of the UK, showing all transactions for those accounts for the preceding seven days.

• Records Retention

  6) The Firm must secure and preserve all records and/or information (physical or electronic) relating to its business, including payment, electronic money and digital services in their original form, or in a copy, provided it is identical to the source material. These must be retained in a form and at a location within the United Kingdom, to be notified to the Authority in writing by 17:00 on 24 January 2025, such that they can be provided to the Authority, or a person named by the Authority, promptly on its request. 7) The Firm must provide written confirmation to the Authority that it is in compliance with the Requirements by 24 January 2025.  These Requirements shall take immediate effect and remain in force unless and until varied or cancelled by the Authority (either on the application of the Firm or of the Authority’s own volition).