Core Ongoing Requirements
These obligations typically apply across all payment-related license categories.
Periodic Reporting
- Transaction volume summaries
- Risk and monitoring metrics
- Material incident disclosures
- Annual declarations
Safeguarding Maintenance
- Ongoing segregation controls
- Reconciliation evidence
- Exception management logs
- Independent oversight review
AML / CFT Programme
- Sanctions screening updates
- Monitoring rule adjustments
- Suspicious activity procedures
- Training and internal audits
Material Change Notifications
Certain operational or governance changes must be formally notified. Delayed disclosure may impact standing under the framework.
- Changes to directors or key compliance officers
- Alterations in safeguarding model
- New product lines or corridor expansions
- Significant ownership changes
Renewal & Maintenance
Annual Renewal
License renewal typically requires confirmation of ongoing compliance and reporting completion.
Supervisory Engagement
Structured responses to data requests, clarifications, or review interactions.
Supervisory interaction is procedural. Maintaining clear documentation and audit trails reduces friction.
Operational Resilience Expectations
Incident Management
Defined escalation and remediation procedures for operational or security events.
Business Continuity
Documented contingency planning for system failures or external disruptions.
Record Retention
Secure and retrievable documentation of transactions and compliance records.
