How do I know my money is safe?
Centtrip Limited is authorised as an Electronic Money Institution (EMI) by the Financial Conduct Authority (FCA) to issue e-money. Centtrip is required to safeguard funds received in exchange for e-money that has been issued.
The specific regulations that Centtrip must comply with are set out in detail within:
- Regulation 20 of the Electronic Money Regulations 2011 (EMRs);
- Payment Services Regulations 2017(PSRs); and
- Chapter 10 of the FCA Approach Document.
How does Centtrip safeguard my money?
Centtrip itself only issues e-money to customers for certain types of transactions and in relation to limited number of currencies. All other e-money is issued by PFS Card Services (Ireland) Limited (PCSIL) pursuant to the terms of an authorised distribution agreement that is in place between Centtrip and PCSIL.
Centtrip is the e-money issuer and will safeguard funds on account which are held in the following currencies:
- AED/UAE Dirhams
- BHD Bahraini Dinar
- CNY Chinese Yuan
- KWD Kuwaiti Dinar
- MXN Mexican Peso
- SGD Singapore Dollar
For all other currencies, PCSIL is the e-money issuer.
Centtrip will also safeguard funds for e-money that is issued as part of carrying out the following types of transactions:
- Settlement of a FX conversion where funds are received after confirmation and onward payment is made to another account following receipt of the sold currency. This means that e-money will be issued by Centtrip in relation to any payment that is directly related to the settlement of an FX conversion where the sold amount is sent to Centtrip after execution of the transaction and onward payment is being made to another account (and not held on account); and
- Settlement of a forward FX conversion. This means that on receipt of the sold currency from the customer, the purchased currency amount is issued as e- money by Centtrip and onward payment made as an e-money related payment.
In all other instances, PCSIL will ensure that relevant funds (which is the Available Balance on the Centtrip Card) are segregated from their operational funds and held in the Customer Funds Account in accordance with the safeguarding requirements of the Electronic Money Regulations 2011. In the event that PCSIL became insolvent those funds would be protected against claims made by any of PCSIL’s creditors.
For e-money issued by Centtrip, we use the segregation method of safeguarding. This means that funds received for e-money are segregated immediately upon receipt and held in safeguarding accounts with our banking partner, Arbuthnot Latham. These funds are held separately from Centtrip’s own operational funds and working capital.
Centtrip does not maintain a safeguarding account for each individual customer. Rather, Centtrip holds pooled accounts in the name of ‘Centtrip Client Money Accounts’ in each currency for the purposes of issuing e-money. Centtrip performs ongoing reconciliations of its safeguarding accounts throughout the working day.
Centtrip’s banking partners have all been requested to provide a warranty that the safeguarded funds will not be used to satisfy or offset any other obligation including those obligations imposed on Centtrip itself. Centtrip’s banking partners and card provider are authorised in the UK and in the European Economic Area (EEA).
Which types of transaction are safeguarded?
In EMRs, safeguarding applies to what are described as 'Relevant Funds'. These are defined as sums received ‘in the form of payment by a payment instrument only have to be safeguarded when they are credited to the EMI’s payment account or are otherwise made available to the EMI, subject to the requirement that they are safeguarded by the end of five business days after the date on which the e-money was issued.’
Centtrip’s own funds must be held on different bank accounts as these monies are not safeguarded.
When does safeguarding apply and for how long?
Safeguarding should start immediately, once 'Relevant Funds' have been ‘credited to the EMI’s payment account or are otherwise made available to the EMI’. Centtrip is then under an obligation to safeguard Relevant Funds up until the point Centtrip has provided a payment instruction to our payment service provider and the funds have been remove from our payment account. At this point, the funds can no longer be said to be within Centtrip’s control.
Can I have confidence in Centtrip’s safeguarding processes?
Centtrip conducts an annual audit of its compliance with the regulatory safeguarding requirements. This audit is performed by external auditors to confirm that Centtrip:
- has up-to-date documented safeguarding systems and controls;
- holds records that demonstrate and explain the rationale behind its safeguarding decisions; and
- fully discharges its safeguarding obligations as prescribed by the relevant legislation.