Financial House Limited

Limits on what they may do

• Restrictions on business activities

  1) The Firm must not, without the prior written consent of the Authority, carry out any electronic money services for which it is authorised by the Authority pursuant to Part 2 of the EMRs or conduct any payment services as defined under regulation 2(1) of the Payment Services Regulations 2017 (“the PSRs”). For the avoidance of doubt, this includes not onboarding any new customers and not accepting any new funds from existing customers.

• Assets requirement

  2) The Firm must not return, transfer, or otherwise deal with any of its clients safeguarded funds that have been received by the Firm in exchange for electronic money (“Relevant Funds”) without the prior written consent of the Authority. 3) The Firm must appoint an independent and suitability qualified third party, to be agreed in advance with the Authority, to oversee the return of Relevant Funds to the Firm’s clients. 4) In respect of Requirement 2, a client may redeem their own funds upon their request to the Firm where the customer due diligence and, where applicable, enhanced due diligence on the client file has been remediated to the satisfaction of the independent third party (appointed in accordance with Requirement 3 above) so that the evidence contained in the client file is sufficient to enable the Firm to comply with its obligations under relevant legislation, including under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”) and the Proceeds of Crime Act 2002 (“POCA”), in respect of the client. 5) The Firm must ensure that all Relevant Funds are appropriately ringfenced in a designated safeguarding account or accounts, in accordance with regulations 20, 21 and 22 of the EMRs. For the avoidance of doubt, if this requires a transfer between accounts, this must only be done with the prior written consent of the Authority.