Purpose
Protect client funds and reduce exposure to payment fraud.
Scope
- • All payment flows involving client money.
Core requirements
- Use documented payment procedures with dual-verification for changes to bank details.
- Avoid commingling client funds with unrelated operational cash where local rules require segregation.
Recommended evidence
- Written payment procedure.
- Anti-fraud training records.
Examples of acceptable practice
- Independent verification of any change to operator payment details.
Examples of problematic practice
- Accepting new payment instructions solely via email without verification.
Jurisdiction notes
- Segregation and safeguarding rules differ significantly by country.
Related knowledge
Change history
| Version | Date | Note |
|---|---|---|
| 1.0 | 2025-01-01 | Initial public draft. |
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