Safeguarding of funds

Is MultiPass a bank?

No, MultiPass is not a bank. We are an Electronic Money Institution (EMI) and a member of SWIFT, which means we can open unique IBAN current accounts for our customers and receive, collect and store their funds for them as well as facilitating FX conversions and processing outbound payments.

Is MultiPass a regulated financial institution?

Yes, MultiPass is authorised and regulated by the UK Financial Conduct Authority (Firm reference number 900840) as an Authorised Electronic Money Institution.

How does MultiPass protect its clients’ money?

As a UK authorised EMI, we are subject to strict licensing, regulation and oversight by the UK Financial Conduct Authority.

Unlike a bank, we are not permitted to loan out money and our customers’ money is not covered by the Financial Services Compensation Scheme - instead The Electronic Money Regulations 2011 (‘EMR’) requires us to take special measures to ‘safeguard’ our customers’ money which is known as ‘relevant funds’.

How does MultiPass ‘safeguard’ client funds?

MultiPass uses the ‘segregation’ method of safeguarding. This means we deposit our clients’ money into segregated bank accounts which are held with the banks who are our authorised credit institution / banking partners.

These segregated bank accounts are designated as ‘client accounts’. They are non recourse, no right of set-off accounts which cannot be used for any purpose other than safeguarding our customers’ deposits for the issuance of e-money.

This means that at all times our customers’ money is securely held separately to our business funds and bank accounts. In the unlikely event of an insolvency, there are special rules in place which mean that the funds safeguarded in our segregated accounts would be paid out to customers in priority to other creditors quickly and efficiently.

Our obligation to safeguard begins when we receive the customers’ money and ends when it is paid out.

What steps does MultiPass take internally to ensure that customers’ funds are securely held within the safeguarding accounts held with authorised credit institutions?

We reconcile our customers’ e-money balances to the actual balances held in our safeguarded bank accounts on a not less than daily basis to ensure that those balances match.

Our safeguarded bank accounts are clearly named and identified as ‘segregated’ accounts by the relevant authorised credit institutions / banks.

Each authorised credit institution/ bank has provided us with an acknowledgement letter confirming that all funds held in our safeguarded bank accounts are segregated and that they have no recourse or right of set off against the funds held in those accounts.

We have implemented strict internal written controls and procedures to ensure that reconciliation processes are carried out, not less than daily in order to ensure that any material discrepancies are quickly identified, rectified and, where relevant, notified to the Regulator.

We carefully review and document solvency / suitability of our authorised credit institution / banking counterparties on an ongoing basis to ensure the security of our customers’ funds.

How can your customers be sure that the safeguarding systems are operating effectively?

We engage an appropriately qualified reputable professional firm to conduct an annual assurance audit our systems and to provide an opinion on:

1. whether we have maintained organisational arrangements adequate to enable us to meet the FCA’s expectations of its compliance with the safeguarding provisions of the EMRs/PSRs (as set out in chapter 10 of our Approach Document), throughout the audit period, and
2. whether we met those expectations as at the audit period end date

A copy of the report is provided to the UK Financial Services Authority who also require us to regularly report to them regarding solvency and about our ongoing operations.

Who owns MultiPass and are you well capitalised?

Yes, as a part of Global Group we are very well capitalised. MultiPass Platforms Limited is wholly owned by the Dyninno Group which was founded in 2004. Our Group is a global business headquartered in San Francisco with offices in 12 countries and more than 5000 employees.Our Travel, FinTech, and EnterTech divisions provide a range of products and services to millions of customers in more than 50 markets worldwide.