Safeguarding & Security — Edwards FX Ltd

When funds are posted to your account, e-money is issued in exchange for these funds, by an Electronic Money Institution who we work with, called Currencycloud. In line with regulatory requirements, Currencycloud safeguards your funds. This means that the money behind the balance you see in your account is held at a reputable bank, and most importantly, is protected for you in the event of Currencycloud's, or our, insolvency. Currencycloud stops safeguarding your funds when the money has been paid out of your account to your beneficiary's account.

The flow at a glance

From your account
to safeguarded protection.

Your business sends GBP, EUR or USD

Funds leave your business bank account via standard UK Faster Payments, SWIFT or SEPA — settled to the account details provided at onboarding.

Held in a segregated safeguarding account

Currencycloud holds client funds in a dedicated safeguarding account at a regulated UK credit institution — legally separate from Currencycloud's operating funds.

FCA FRN 900199 · EMR 2011

Reconciled daily, never commingled

Currencycloud reconciles the safeguarded account daily against its books. In the unlikely event of insolvency, your funds are protected and returned to you ahead of any general creditors.

This visualisation summarises the regulated flow. The detailed mechanics, regulatory references and your recourse are explained in the sections below.

Trust by design

Identity, encryption
and verifiable audit.

Every client interaction passes through layered controls — identity verification at onboarding, encrypted payment messaging in transit, hardware-backed key storage at rest, and an immutable audit trail across the full lifecycle of a transaction.

Multi-factor identity — biometric and document verification at onboarding, ongoing PEP and sanctions screening
End-to-end encryption — TLS 1.3 in transit, AES-256 at rest, hardware security modules for cryptographic operations
Immutable audit trail — every quote, instruction, settlement and reconciliation timestamped and retained for six years
Independent assurance — annual external audit of safeguarding, ISO 27001-aligned controls and SOC 2-style operational testing

Identity, biometric, encryption and audit controls

Edwards FX Ltd is the customer-facing brand. Our payment services are delivered by Currencycloud, an FCA-authorised Electronic Money Institution. This is the most important thing to understand: your regulated relationship is with Currencycloud, even though your day-to-day relationship is with us.

Regulatory Position

Currencycloud is authorised and regulated by the Financial Conduct Authority as an Authorised Electronic Money Institution under Firm Reference Number 900199. You can verify this directly on the FCA Register. Currencycloud operates under the Electronic Money Regulations 2011, which is the UK's implementation of the EU Payment Services Directive.

Authorised Electronic Money Institution status carries specific obligations around how client funds are handled, capital adequacy, governance, complaints handling, and protection of customer data. The FCA supervises this on an ongoing basis, including through annual reporting, audited financial statements, and ad-hoc supervisory engagement.

All client onboarding is subject to enhanced due diligence under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — commonly referred to as MLR 2017 — conducted by our FCA-authorised payment partner Currencycloud. No business relationship is established, and no funds are accepted, until KYB is complete.

Statutory Framework

Onboarding, ongoing monitoring, and transaction screening operate under MLR 2017, the Proceeds of Crime Act 2002, the Joint Money Laundering Steering Group (JMLSG) guidance, and the FCA's Financial Crime Guide. Currencycloud, as an FCA-authorised Electronic Money Institution (FRN 900199), is the regulated entity responsible for compliance with these obligations.

What's checked before we accept a client

Know Your Business (KYB): verification of UK incorporation via Companies House, registered office, trading address, and confirmation that the business is genuine and active
Beneficial ownership: identification and verification of all individuals owning or controlling 25% or more of the company, in line with the Persons with Significant Control (PSC) regime
Director and signatory checks: identity verification, sanctions screening, and politically-exposed-person (PEP) screening for every director and authorised user on the account
Source of funds: evidence-based assessment of where client money will originate, with enhanced due diligence applied to higher-risk profiles
Purpose of the relationship: documentation of the commercial rationale for the FX activity — supplier payments, payroll, treasury, etc. — to enable transaction monitoring against expected behaviour

Ongoing monitoring

Transaction monitoring against the client's documented expected activity, with automated rules and human review for outliers
Periodic refresh of KYB and beneficial-ownership data on a risk-based cycle
Real-time sanctions screening against UK, EU, US and UN consolidated lists for every payment instruction
Suspicious Activity Report (SAR) filing with the National Crime Agency where required by law

Edwards FX Ltd does not itself receive, hold, or transfer client funds, and is not a regulated person under MLR 2017. All regulated AML and KYB obligations are discharged by Currencycloud as the FCA-authorised Electronic Money Institution standing behind the service.

"Safeguarding" is the regulatory term for how an Electronic Money Institution protects client money. Under the Electronic Money Regulations 2011, an authorised EMI is required to keep customer funds completely separate from its own operating funds, in dedicated accounts at a credit institution.

What this means in practice

Funds you send to Currencycloud for an FX trade or pending payment are held in a segregated safeguarding account at a UK credit institution
Those funds are not used by Currencycloud for its own operating expenses, lending, or any other business activity
Safeguarded balances are reconciled daily against the customer ledger to ensure the safeguarded total always equals the sum of customer entitlements
The arrangements are subject to independent annual audit as part of Currencycloud's regulatory reporting
In the unlikely event of Currencycloud's insolvency, safeguarded client funds are protected from creditors and returned to clients ahead of other claims

The flow of funds for a typical trade

You instruct a trade — e.g. selling £100,000 to buy USD for a supplier payment
You transfer the £100,000 to your safeguarded account from your business bank
The funds sit in the safeguarding account at a credit institution while the trade is booked and confirmed
On settlement, the converted USD is paid out to your beneficiary via SWIFT or local rails
Your statements and the safeguarded ledger are updated; the audit trail is preserved

At no point in this flow are your funds commingled with Currencycloud's own money, and at no point are they used for anything other than completing your instructions.

Authorised Electronic Money Institutions like Currencycloud are not deposit-taking banks, and the funds you hold with them are not deposits. This means safeguarding is not the same as FSCS protection — the £85,000 deposit protection scheme that applies to bank current accounts and savings.

However, the protections you get under safeguarding are arguably more direct than FSCS, because:

Safeguarding has no upper limit — every penny held in your name is protected, not just the first £85,000
Funds are kept separate from the firm's own assets at all times, rather than relying on a compensation scheme paying out after a failure
In an insolvency, safeguarded client funds do not form part of the insolvent estate — they are returned to clients directly

The trade-off is that safeguarding does not protect you against losses from market movements, fraud you authorise yourself, or operational issues at any party in the chain. It specifically protects against the failure of the Electronic Money Institution itself.

05 · The Chain

Who does
what.

A clear picture of where each party sits in the chain — and which regulator is responsible for each.

Front Office

Edwards FX Ltd

Client-facing distribution and service. Brings clients onto the platform, provides dealing support, and manages the day-to-day commercial relationship. Not authorised by the FCA in its own right; operates as introducer and distributor of regulated payment services.

Regulated Provider

Currencycloud

The FCA-authorised Electronic Money Institution (FRN 900199). Provides the regulated payment services, holds client funds in safeguarded accounts, executes the FX and outbound international payments, and is supervised directly by the Financial Conduct Authority.

Custody

Safeguarding Banks

UK credit institutions where client funds are physically held in segregated safeguarding accounts. These accounts are designated under the Electronic Money Regulations 2011 and are reconciled daily.

Safeguarding is one part of how we keep clients secure. The other parts are operational: how we authenticate users, protect data, monitor transactions, and respond when things go wrong.

Access & authentication

Multi-factor authentication on every login
Role-based permissions for multi-user accounts (maker–checker on payments)
Encrypted sessions, with automatic timeout on inactivity

Data protection

UK GDPR compliance for all personal data handling
Data encrypted in transit and at rest
Customer data held only as long as required by AML and tax record-keeping rules

Transaction monitoring & AML

Currencycloud performs full KYB and KYC at onboarding under the Money Laundering Regulations 2017
Real-time transaction monitoring for unusual patterns
Sanctions screening on every payment, every counterparty
Suspicious Activity Reports made to the National Crime Agency where required by law

If you have a concern about a transaction, the service you've received, or anything else about your account, here's the path.

First: speak to your dealer

Most issues are resolved on the same call. Your dedicated dealer or the dealing desk can usually answer queries about specific trades, payment status, or fees within minutes.

Next: formal complaint

If your dealer can't resolve it to your satisfaction, you can raise a formal complaint. Edwards FX will acknowledge receipt within two business days and investigate. For matters relating to the regulated payment service itself, the complaint will be passed to Currencycloud as the regulated provider, in line with the FCA's complaint-handling rules in DISP.

Full details on our complaints procedure here.

Independent review: the Financial Ombudsman Service

If you remain dissatisfied after Currencycloud's final response (or after eight weeks have passed without one), you can refer the matter to the Financial Ombudsman Service. The FOS provides an independent, free dispute-resolution service for consumers and eligible small businesses. They can be reached at financial-ombudsman.org.uk.

Questions

Want to dig
deeper?

If you'd like to see the safeguarding arrangements documented in more detail before opening an account — or have a treasurer who needs to satisfy internal due diligence — we're happy to walk through it.

Speak to a Dealer Verify on FCA Register

Payment services for Edwards FX Ltd are provided by Currencycloud, authorised by the Financial Conduct Authority as an Authorised Electronic Money Institution (FRN 900199).