A pre-licence safeguarding checklist for new e-money teams
Bank letters, account titling, and staffing the reconciliation seat before you accept the first customer load.
Launch pressure tempts teams to polish the product while safeguarding arrangements stay “almost ready.” Regulators and banks rarely accept almost.
Before the first customer credit lands, confirm that safeguarding accounts exist with correct legal naming, that inflow and outflow paths are documented, and that insolvency language in bank or trustee letters matches your operating model. Assign a named reconciliation owner with a trained deputy—weekends and public holidays included.
Policies should describe shortfall funding, not only segregation ideals. Test a dry-run close with sample wallet balances and merchant settlement files. If the dry run needs heroic manual fixes, your control design is not launch-ready.
Our pre-licence readiness review walks founders and compliance leads through these points in Wan Chai working sessions or remote walkthroughs, then leaves a go-live conditions list your board can track.