Know where you stand on safeguarding before your first audit.
A two-week, fixed-price Compliance MOT for UK payment and e-money firms. You get a clear red, amber and green view against the FCA's new safeguarding rules, and a 90-day plan to fix what matters most.
The FCA has turned safeguarding guidance into detailed rules.
Policy Statement PS25/12 added a new rulebook, CASS 15, for authorised payment institutions, e-money institutions and small e-money institutions. Most firms built their processes before it existed. The first annual audits will show where they fall short.
Records that show each customer's money
Allocate receipts by the next business day, track unallocated and unidentified funds, and reconcile every working day.
Paperwork an administrator can use
A resolution pack, acknowledgement letters on the FCA template, and dated due diligence on every safeguarding bank.
Reporting the FCA will check
A monthly safeguarding return, an annual audit by a qualified auditor, and prompt notification of any breach.
A clear answer, and a plan your team can follow.
40 requirements, checked
Your policies, records and controls reviewed against every applicable rule, with sample reconciliations tested.
Red, amber and green
A short report your board can read in ten minutes, with each finding tied to its rule reference.
90-day fix plan
Who does what, by when, with the urgent items first. Ready to share with your auditor.
Findings call
One hour with your leadership team to walk through the findings and agree priorities.
Ten working days, about three hours of your team's time.
You share documents once. I do the reading, the testing and the writing.
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Day 1Kick-off and document requestA 45-minute call and a short checklist of what to send.
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Days 2–8Review and testingPolicies, letters, the resolution pack and a sample of reconciliations.
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Day 9Report and planYour red, amber and green report and 90-day plan.
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Day 10Findings callWe agree priorities and owners together.
The fee depends on how many accounts, currencies and safeguarding methods you use. You'll have a written quote within a day of our call. 50% on kick-off, 50% on delivery.
Ask for a quoteHelp working through the fix plan, preparing for your safeguarding audit, and keeping your resolution pack and letters current. Priced to scope.
I'm Suliat Ogunlende. I've built regulated payment operations from the inside.
I've led FCA licensing for a UK payments business and served as COO and executive board member of a payments scale-up. Over more than 15 years I've run operations, governance and regulatory delivery across the UK, the US, and the Middle East and Africa.
I know what an auditor will ask for, and what a small team can realistically fix in a quarter. That's what this review is built around.
From my in-house roles
Names are withheld for confidentiality. These are roles I held, not client engagements.
From licence application to live regulated operations
Led the FCA licensing workstream, then ran governance and operations for a regulated payments service with 150+ business clients across 12 countries.
Operations and governance through rapid growth
Built the operating model and board-level governance as the team grew 350%, through a major funding round.
Questions firms ask first
Who is this for?
Authorised payment institutions, e-money institutions, small e-money institutions, and small payment institutions that have opted in to safeguarding.
Does this replace our safeguarding audit?
No. The audit must be done by a qualified auditor. The MOT gets you ready for it, so there are fewer surprises.
Is this legal advice?
No. It is an operational gap assessment. Where a point needs a legal view, I'll say so.
How do you handle our documents?
Under a signed confidentiality agreement. Please remove customer personal data before sharing; I only need your policies, records and sample reconciliations.
Do you work with our competitors?
I check for conflicts before every engagement and will tell you if one exists. Nothing you share is used for any other client.
We hold under £100,000. Does this still apply?
You may not need an annual audit, but the rest of CASS 15 still applies, including daily reconciliations and the resolution pack.
Start with a 15-minute call.
Tell me how you safeguard today. I'll tell you whether an MOT is worth it.