Terms of Service

Brit FX Limited — Effective Date [ ]

1. Introduction

These Terms of Service (“Terms”) constitute a legally binding agreement between you (“Client”, “you”, or “your”) and Brit FX Limited, trading as Qore Finance (the “Company”, “we”, “us”, or “our”) governing your access to and use of the services provided by the Company.

These Terms apply to all services made available by us, including but not limited to payment initiation services and remittance services and access to partner-based financial infrastructure and their services.

By:

  • accessing our website or platform,
  • submitting an application, or
  • using any of our services,

you confirm that:

  • you have read and understood these Terms,
  • you agree to be bound by them, and
  • you have the legal capacity to enter into a binding agreement.

If you do not agree with these Terms, you must immediately cease using the services. You should download a copy of these Terms for future reference. You can also request a copy of these Terms from us at any time. We will provide this to you free of charge in a durable medium (e.g. by email or download from our platform) within a reasonable time of your request.

If you have any questions about these terms, you can contact us via email info@qore.finance.

1.1. Contractual Relationship

These Terms govern the relationship between you and us only. Where services are delivered through regulated third-party partners, separate terms and conditions may apply. We will make clear to you, before or at the point of each transaction, which entity is responsible for which element of the service.

1.2. Changes to Terms

We may propose changes to these Terms or to the information we are required to provide you. We will notify you of any proposed changes via email to your registered address at least two months before the date on which they are to take effect.

If you do not notify us that you reject the proposed changes before they take effect, you will be deemed to have accepted them. You have the right to terminate these Terms without charge at any time before the proposed effective date of the changes by notifying us using the contact details in Section 2.2.

Changes to reference interest or exchange rates may be applied immediately and without notice where permitted, for example where the change is based on an agreed published reference rate or is more favourable to you. Any change to interest or exchange rates will be applied in a neutral manner that does not discriminate against you.

1.3. Duration

This agreement is made for an indefinite period. It commences on the date on which your onboarding is successfully completed and continues until terminated by either party. Your right to terminate this agreement, and our right to terminate, are set out in Section 10.

1.4. Interpretation

Where these Terms refer to any law, regulation or statutory instrument, that reference includes any amendment, re-enactment, replacement or subordinate legislation made under it from time to time.

2. Company Information

The services are provided by Brit FX Limited, trading as QORE Finance, a company registered in England and Wales under company number 12309386.

2.1. Regulatory Status and Permissions

Brit FX Limited is registered with the Financial Conduct Authority as a Small Payment Institution. Our regulator is the Financial Conduct Authority, 12 Endeavour Square, London E20 1JN (www.fca.org.uk). Our registration can be verified on the FCA Register at register.fca.org.uk using Firm Reference Number 918317.

Our registration permits us to provide the Money Remittance services and Payment services within the United Kingdom.

Our registration as a Small Payment Institution does not permit us to:

  • accept deposits;
  • issue payment cards;
  • provide credit or lending products;
  • provide any payment service that falls outside our registered permissions.

We are not a bank and we are not authorised to carry out any activity beyond the scope of our FCA registration.

Certain services described on the platform may be provided by regulated third-party partners, or subject to additional regulatory requirements depending on the jurisdiction and transaction type.

2.2. Contact Details

Registered Office

Suite 30, 15a Market Street, Telford, England, TF2 6EL

Operating Address

Parallel House, 32 London Road, Guildford, Surrey, GU1 2AB

Email

info@qore.finance

2.3. Communication

Communication Channels. The primary channel for all regulatory notices, including notices of changes to these Terms and termination notices, is email to your registered email address. We may also contact you by telephone, post, or platform notification where appropriate.

Technical requirements on your side. You are responsible for ensuring that your contact details are accurate and up to date at all times and for checking communications from us promptly. If your contact details change, you must notify us without undue delay.

To receive information and notifications from us electronically you will need a valid email address, a reliable internet connection, and a compatible web browser (current or immediately preceding version of Chrome, Firefox, Safari, or Edge).

We are not responsible for any loss arising from your failure to receive a communication where that failure results from inaccurate, outdated, or incomplete contact details held on your account.

Frequency of Communications. We will provide you with a statement of your payment transactions at least once per month, free of charge, by email in a durable format or through your online account. If you would prefer to receive statements by a different method or at a different frequency, please contact us to discuss.

Each statement will include:

  • a reference enabling you to identify each transaction;
  • the amount;
  • any charges applied;
  • the exchange rate used where applicable; and
  • the debit or credit value date.

2.4. Language

These Terms are provided in English. Where translations are provided, the English version shall prevail in the event of any inconsistency.

2.5. Right to Receive Terms

You may request a copy of these Terms and the information at any time during our relationship. We will provide this to you free of charge in a durable medium within a reasonable time of your request.

3. Services

3.1. Services Provided by Us

Brit FX Limited is a Small Payment Institution. We are registered (not authorised) by the Financial Conduct Authority (FCA). Our registration permits us to provide the remittance and payment services listed below within the United Kingdom.

  • Money Remittance — Receiving funds from you and transmitting them to a payee or another payment service provider on your behalf, without us maintaining a payment account in your name.
  • Payment Services — Initiating payment orders from a payment account held with another provider, at your request.

We do not maintain payment accounts for customers or hold funds on an ongoing basis. Our total payment transaction volume is subject to a cap of £3 million on average per month, calculated over the preceding 12 months across all payment services we provide. If our average monthly transaction volume reaches or is likely to reach £3 million, we are required to apply to the FCA for full authorisation as an Authorised Payment Institution before that threshold is breached.

To facilitate services we may engage with the partner that can facilitate the payments above the threshold.

3.2. Services Provided by Our Partners

Certain services are delivered through regulated third-party partner Global Currency Exchange Network Ltd. Global Currency Exchange Network Ltd (FRN 504346) is authorised by the Financial Conduct Authority (FCA) under the Payment Services Regulations 2017. These services include:

  • enabling cash to be placed on a payment account and operating payment account;
  • executing payment transactions;
  • enabling movement of funds between different jurisdictions;
  • payments involving different currencies;
  • access to foreign exchange (FX) and payment infrastructure;
  • support services related to transaction execution, monitoring, and administration.

To access services provided by our partners, you may be required to:

  • enter into separate agreements with such partner(s), or
  • accept their terms and conditions.

We do not guarantee that all services will be available in all jurisdictions or to all clients. We are not responsible for the performance, acts, or omissions of third-party providers, except where required by law for delays or failures caused by such partners.

Where foreign exchange services are involved:

  • exchange rates may be provided by third-party providers;
  • rates may fluctuate and are not guaranteed until execution;
  • we are not liable for market movements or rate changes.

3.3. Consent and Withdrawal of Consent

For recurring or future-dated payments, you may withdraw consent by notifying us by email to info@qore.finance at any time before the payment order becomes irrevocable. A payment order for a future-dated transaction becomes irrevocable at 09:00 am on the scheduled execution date. We will confirm the point of irrevocability for any specific transaction on request.

4. Eligibility

4.1. General Requirements

Our services are provided to corporate clients and businesses. We do not offer services to private individuals as a standard part of our business. Applications from individuals may be considered on a case-by-case basis at our discretion, subject to our risk-based assessment.

To be eligible to use our services, you must:

  • be a validly incorporated legal entity in good standing in your jurisdiction of incorporation, or an individual accepted by us following a risk-based review;
  • have full legal capacity to enter into binding agreements;
  • where acting on behalf of a legal entity, be duly authorised to do so by that entity;
  • provide accurate, complete, and up-to-date information as required during onboarding, including but not limited to proof of identity, proof of address, evidence of legal existence, ownership structure, and any additional documentation we may request;
  • successfully complete all onboarding, verification, and compliance checks to our satisfaction.

We reserve the right to decline any application that falls outside our risk appetite, without being required to give reasons, except where we are required to do so by law.

4.2. Compliance and Verification

Where you are a legal entity, you must satisfy the following requirements as a condition of accessing our services.

Legal status. You must be validly incorporated and in good standing in your jurisdiction of incorporation or registration. We may require evidence of this at any time, including during periodic reviews of our relationship.

Documentation. You must provide, and keep current throughout our relationship, documentation evidencing:

  • your legal existence, such as the certificate of incorporation or equivalent, registered address, and details of your principal business activities;
  • the ownership structure, including a complete and accurate picture of your corporate structure, identifying all direct and indirect shareholders and the chain of ownership up to the ultimate beneficial owner level;
  • your ultimate beneficial owners (UBOs), being any natural person who directly or indirectly owns or controls more than 25% of your shares or voting rights, or who otherwise exercises control over the management of your organisation;
  • in certain circumstances, and where our risk assessment requires it, we may request identification and verification of individuals who hold or control 10% or more of your shares or voting rights.

4.3. Restricted and Prohibited Clients

We may refuse, restrict, or terminate services where you fall outside our Risk Appetite Policy.

In particular, we will not provide services where:

  • you are located in, incorporated in, or connected to a jurisdiction subject to OFSI, UN, OFAC, EU, or FATF sanctions or restrictions;
  • your business involves or a transaction relates to any activity that is unlawful or prohibited under our Risk Appetite Policy, including money laundering, terrorist financing, sanctions evasion, weapons, controlled substances, human trafficking, unlicensed gambling, or fraud;
  • you fail to provide documentation required for customer due diligence under the Money Laundering Regulations;
  • you cannot demonstrate a legitimate source of funds or source of wealth to our satisfaction;
  • our risk assessment places you outside our Risk Appetite Policy at any point during our relationship.

Where you are identified as high risk, including politically exposed persons or clients with connections to high-risk jurisdictions or sectors, we may apply enhanced due diligence as a condition of service.

We may be unable to give reasons for a refusal where doing so would constitute a tipping-off offence under the Proceeds of Crime Act 2002 or the Terrorism Act 2000. We will not be liable for any loss arising from a refusal or restriction taken in good faith in accordance with this clause or our Risk Appetite Policy.

4.5. Right to Refuse, Suspend or Terminate

We may suspend your access to services pending investigation where you breach these Terms or fail to provide requested information. Where a breach is sufficiently serious and falls within one of the grounds in Section 10.2, termination without advance notice may follow. Where it does not fall within those grounds, termination will be subject to the notice requirements in Section 10.1.

Refusal of onboarding may follow where:

  • we are unable to complete customer due diligence or verification in accordance with our obligations under the Money Laundering, Terrorist Financing Regulations;
  • you do not meet our eligibility criteria or fall outside our Risk Appetite Policy;
  • onboarding you would cause us to breach any legal or regulatory obligation.

Suspension of access. We may suspend your access to our services, without prior notice where necessary, where:

  • we have reasonable grounds to suspect that your account or a payment service provided under this agreement has been used, is being used, or is likely to be used in connection with fraudulent, criminal, or unauthorised activity;
  • we are required to do so by the FCA, HM Treasury, the Secretary of State, or any other competent authority;
  • we have security concerns relating to your personalised security credentials;
  • we are required to apply enhanced due diligence measures and are unable to do so without suspending the service.

When we suspend access, we will inform you of the suspension and the reasons for it, either before the suspension takes effect or immediately afterwards, unless doing so would compromise a legal investigation, breach a legal obligation, or is otherwise prohibited by law.

4.6. Your Responsibility

Accuracy of information. You must ensure that all information you provide to us, whether at the onboarding stage or throughout our relationship, is accurate, complete, and not misleading. If any information you have provided changes or becomes inaccurate at any point, you must notify us without undue delay.

This includes but is not limited to changes to your:

  • name, address, or contact details;
  • business activities or ownership structure;
  • ownership or control, including changes to ultimate beneficial owners;
  • source of funds or source of wealth;
  • payment account details.

Where you provide incorrect or incomplete information, we may be unable to execute payment transactions on your behalf, may be required to apply enhanced due diligence, or may be entitled to terminate this agreement without advance notice.

Compliance with applicable law. You must ensure that your use of our services complies with all laws and regulations applicable to you, including anti-money laundering and counter-terrorist financing obligations, sanctions and export control requirements, and tax reporting obligations. We are not responsible for advising you on your legal or regulatory obligations.

Prohibited use. You must not use our services for any unlawful, fraudulent, or prohibited purpose. A full list of prohibited activities is set out in our Risk Appetite Policy.

5. Charges, Interest and Exchange Rates

5.1. Pricing Agreement

We charge for the services we provide, including payment transfers, currency conversion, and any special tasks carried out on your behalf. All charges, fees, FX margins, and rates applicable to your account are set out in your Pricing Agreement, which will be disclosed, agreed, and signed with you before services begin and which forms part of your agreement with us.

We will not charge you for providing or making available information that we are required to provide under the Payment Services Regulations.

5.2. Third-Party Charges

Transactions may be routed through third-party providers, including correspondent banks and payment intermediaries, who may apply their own processing or routing charges. Where such charges are predictable, we will disclose them to you before execution.

Where they cannot be predicted in advance, we will make you aware of the basis on which they may arise.

5.3. Currency Conversion

Where your instruction involves a currency other than sterling, an exchange rate will be applied. The reference rate used as the basis for currency conversion is a mid-market rate at the time of execution. Our margin or spread above that reference rate is set out in your Pricing Agreement. Changes to the reference rate may be applied immediately. Exchange rates are not guaranteed until the point of execution. We will disclose the specific rate applicable to your transaction before execution, in accordance with regulations giving you the opportunity to confirm or cancel before the transaction proceeds.

5.4. Payment of Fees

All charges are payable in full in accordance with your Pricing Agreement. Fees may be deducted directly from the transaction amount or from your account. FX margins are applied at the time of execution and deducted from the payment amount. A negative balance on your account is not permitted.

Failure to pay fees when due may result in suspension of services or refusal to process further transactions until the outstanding amount is settled.

5.5. Changes to Fees

Any changes to the charges applicable to your account will be made in accordance with your Pricing Agreement and notified to you in accordance with clause 1.2 of these Terms. We will give you at least two months’ written notice of any proposed changes to charges before they take effect, during which time you have the right to terminate these Terms without charge.

5.6. Burden of Proof

Where any question arises as to whether we have provided you with information that we are required to provide under the Payment Services Regulations, the burden of proving such information rests with us and not with you.

6. Safeguarding

6.1. Nature of Funds Handling

We do not act as a deposit-taking institution. Funds you provide to us in connection with a payment instruction are received solely for the purpose of executing that instruction. We do not hold funds on an ongoing basis and they are not available to our general creditors.

Funds held by us are not deposits and are not covered by the Financial Services Compensation Scheme (FSCS).

6.2. Safeguarding Arrangements

Relevant funds are protected through safeguarding. This means that any funds held in connection with your payment instruction are kept strictly separate from our own company funds and are held in a dedicated safeguarding account with a bank that is authorised and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. This ensures that your funds are ringfenced and protected from the claims of our creditors in the event of our insolvency. Where the execution of your payment instruction requires funds to be held by our regulated third-party partner, Global Currency Exchange Network Ltd (FRN 504346), they are subject to that partner’s own safeguarding arrangements, maintained in accordance with its regulatory obligations. We conduct due diligence on our partners to ensure that funds are handled in accordance with applicable regulatory and safeguarding requirements.

Regardless of whether funds are held by us or by a regulated partner, they remain ringfenced, are not deposits, and are not covered by the FSCS.

7. Security and Corrective Measures

7.1. Security of Your Credentials

You must take all reasonable steps to keep any personalised security credentials such as login passwords, one-time passcodes, and any other security information used to access our services or authenticate a payment instruction, safe and confidential. In particular you must:

  • never share your credentials with any third party, including anyone claiming to represent us;
  • not record your credentials in any form that could be recognised or accessed by others;
  • log out of your account or platform session after each use;
  • keep your registered contact details accurate and up to date so that we can reach you in the event of a security concern;
  • notify us immediately if you believe your credentials have been lost, stolen, compromised, or used without your authorisation.

7.2. Reporting Security Concerns

If you suspect that your credentials have been compromised, that a payment has been made without your authorisation, or that your account has been accessed by an unauthorised person, you must notify us without undue delay by contacting us at:

The sooner you notify us, the sooner we can act to prevent further loss. Delay in notifying us may affect your liability for any resulting loss as set out below.

7.3. How We Will Contact You About Fraud or Security

We will only contact you regarding suspected fraud, security threats, or account concerns through our verified communication channels, being email from our registered domain or telephone from our registered number.

We will never ask you to disclose your full password, one-time passcode, or any other security credential by telephone, email, text message, or any other channel. If you receive a communication purporting to be from us that requests your credentials, you should treat it as fraudulent and notify us immediately.

7.4. When We May Suspend or Stop Transactions

We reserve the right to stop or prevent the execution of a payment instruction or to suspend access to our services on objectively justified grounds, including where:

  • we have security concerns relating to your credentials or account;
  • we suspect that a payment instruction has been initiated without your authorisation;
  • we reasonably suspect fraudulent or criminal activity in connection with your account;
  • we are required to do so by the FCA, HM Treasury, the Secretary of State, or any other competent authority.

Where we take such action, we will inform you of the suspension and our reasons for it, either before it takes effect or immediately afterwards, unless doing so would compromise a legal investigation.

7.5. Your Liability for Unauthorised Transactions

Your liability for losses arising from unauthorised payment transactions is determined as per below:

  • if you have acted fraudulently, you are liable for all losses without limit;
  • if you have failed to keep your credentials safe with intent or gross negligence, you may be liable for all losses arising from unauthorised transactions;
  • in all other cases, your maximum liability for losses from unauthorised transactions occurring before you notify us is capped at £35;
  • once you have notified us of a loss, theft, or compromise of your credentials, you will not be liable for any further losses from unauthorised use of those credentials, except where you have acted fraudulently.

7.6. Our Liability for Unauthorised Transactions

We are liable for an unauthorised transaction and will provide a full refund where:

  • the transaction was executed without your consent and you notify us without undue delay and within 13 months of the debit date;
  • the transaction occurred after you notified us of the loss, theft, or compromise of your credentials — from the point of notification we bear full liability;
  • the transaction occurred before notification and you did not act fraudulently, did not fail to keep your credentials safe with gross negligence, and did not intentionally breach your security obligations (in those circumstances your liability is capped at £35 and we are liable for the remainder);
  • we failed to apply strong customer authentication where required;
  • the transaction resulted from a technical failure or processing error on our part.

We will provide the refund as soon as practicable, unless we have reasonable grounds to suspect fraud and have notified the relevant authority under the Proceeds of Crime Act 2002.

7.7. Non-Execution or Defective or Late Execution

Where we fail to execute, or incorrectly or late execute, a payment transaction for which we are responsible as the payer’s payment service provider, we are liable and we will:

  • refund the full amount of the non-executed or defective transaction to you and restore your account to the position it would have been in had the defective transaction not taken place, where we are the payer’s payment service provider;
  • make reasonable efforts to trace the payment where it has not reached the payee’s payment service provider and notify you of the outcome of that trace;
  • where the failure is one of late execution, ensure that the payee’s payment service provider credits the amount to the payee’s account with a value date no later than the date on which the amount would have been credited had the transaction been correctly executed;
  • when crediting a refund or restoring your account, the credit value date will be no later than the date on which the original amount was debited.

Regardless of where liability rests, we will on your request immediately and free of charge make efforts to trace any non-executed or defectively executed payment transaction and notify you of the outcome.

8. Complaints

8.1. Complaints Procedure

If you are dissatisfied with any aspect of our service, please contact us in the first instance:

Email

info@qore.finance

Post

Brit FX Limited, Parallel House, 32 London Road, Guildford, Surrey, GU1 2AB

We will acknowledge your complaint promptly. We will aim to resolve it and provide you with a final response within 15 business days of receipt. In exceptional circumstances where we are unable to respond within 15 business days, we will notify you of the delay, explain the reason, and provide our final response within 35 business days of the original receipt of your complaint.

8.2. Financial Ombudsman Service

If you are not satisfied with our final response, or if 35 business days have passed without a final response, and you are an eligible complainant, you may refer your complaint to the Financial Ombudsman Service (FOS) free of charge. Eligible complainants include consumers, micro-enterprises, charities, and small businesses as defined by FCA rules.

You must refer your complaint to the FOS within six months of the date of our final response letter. The FOS will not generally consider a complaint referred outside this period.

The Financial Ombudsman Service can be contacted as follows:

Website

www.financial-ombudsman.org.uk

Telephone

0800 023 4567 (free from landlines and mobiles) or 0300 123 9123

Email

complaint.info@financial-ombudsman.org.uk

Post

Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London E14 9SR

We are subject to the jurisdiction of the Financial Ombudsman Service. Using the FOS is free of charge and does not affect your right to take legal proceedings.

8.3. Governing Law

These Terms and any disputes arising from them shall be governed by and construed in accordance with the laws of England and Wales.

The parties agree that the courts of England and Wales shall have exclusive jurisdiction, unless otherwise required by applicable law.

9. Transaction Execution

All transactions initiated by you are subject to compliance, risk, and regulatory checks. They may be delayed for compliance reasons. Below are the standard processing times.

9.1. Time of Receipt

A payment order is deemed received by us on the business day on which it reaches us, provided it is received before our cut-off time. Payment orders received after the cut-off time, or on a non-business day, are treated as received on the next business day.

9.2. Cut-off Times

Our cut-off time for same-day processing is 15:00 UK time on business days. Business days are Monday to Friday, excluding UK public holidays.

9.3. Maximum Execution Times

We will execute payment transactions within the following timeframes from the date of receipt of your payment order:

  • UK sterling transfers (Faster Payments) — by the end of the next business day (D+1);
  • Euro transfers within the qualifying area — by the end of the next business day (D+1);
  • Other currency transfers — by the end of the fourth business day (D+4) after receipt.

9.4. Information You Must Provide

To initiate a payment instruction with us, you must provide the following information (the ‘unique identifier’) relevant to the transaction type. For UK GBP transfers:

  • the payee’s legal name;
  • sort code (6 digits); and
  • account number (8 digits).

For international transfers:

  • the payee’s legal name;
  • payee’s IBAN;
  • BIC/SWIFT code;
  • any additional reference required by the payee or by us to process the instruction.

Payment transactions will be executed in the currency agreed between us at the time of your instruction. You must specify the currency of the transaction when submitting your payment order. We will not substitute a different currency without your prior agreement. We will execute payment instructions based on the unique identifier you provide. We are not liable for non-execution or defective execution arising from an incorrect unique identifier provided by you. We may request verification of a payment instruction before execution where we consider this necessary.

9.5. Information We Provide About Outgoing Transactions

We will provide or make available to you the following information:

  • a reference enabling you to identify the payment transaction and, where appropriate, information relating to the payee;
  • the amount of the payment transaction in the currency in which your account is debited or in the currency used in the payment order;
  • all charges payable by you in respect of the payment transaction, with a breakdown of those charges where applicable, and any interest payable by you;
  • where a currency conversion was applied, the exchange rate used and the amount of the transaction after that currency conversion;
  • the debit value date or the date on which we received your payment order.

9.6. Information We Provide About Incoming Transactions

We will provide or make available to you the following information:

  • a reference enabling you to identify the payment transaction and the payer, together with any information transferred with the payment transaction;
  • the amount of the payment transaction in the currency in which the funds are credited to your account;
  • all charges payable by you in respect of the payment transaction, with a breakdown of those charges where applicable, and any interest payable by you;
  • where a currency conversion was applied by us as your payment service provider, the exchange rate used and the amount of the payment transaction before that currency conversion was applied;
  • the credit value date.

9.7. Monthly Statements

We will provide you with a monthly statement free of charge. Statements will be provided in a durable medium that allows you to store, access, and reproduce it unchanged, by email or you can view it on our portal.

You may at any time request a statement in paper form. We will provide one paper statement per month free of charge. Additional paper statements requested beyond one per month may be subject to a charge in accordance with your Pricing Agreement.

10. Termination

10.1. Termination by Us with Notice

Contracts entered into before 28 April 2026. Where the contract was entered into before 28 April 2026, we may terminate it by giving you at least two months’ written notice. The notice will be provided by email.

Contracts entered into on or after 28 April 2026. Where the contract was entered into on or after 28 April 2026, we will provide you with a written notice of termination that:

  • contains an explanation of the reasons for termination that is sufficiently detailed and specific to enable you to understand why we are terminating the contract;
  • advises you how to make a complaint to us about the termination; and
  • advises you of your right to refer a complaint to the Financial Ombudsman Service.

The notice of termination will be given at least 90 days before termination takes effect. The notice will be provided by email.

We may terminate without the 90-day period (but still provide you with a notice) where:

  • we consider your conduct towards our staff members amounts to an offence under the Public Order Act 1986, the Protection from Harassment Act 1997, or equivalent legislation in Scotland or Northern Ireland; or
  • you provided materially incorrect information when entering into this contract and we would not have entered into it had we known the correct information.

We cannot use a mutual agreement to end this contract as a way of avoiding our obligation to give you proper notice and reasons under this Section 10. These obligations apply regardless of how any agreement to end the relationship is framed and cannot be waived by agreement between us.

10.2. Termination by Us Without Notice

We are not required to provide a termination notice where:

  • we are required to apply customer due diligence measures under the Money Laundering Regulations and are unable to do so;
  • a relationship must be exited under the Immigration Act 2014;
  • we have reasonable grounds to believe that our services have been used, are being used or will be used in connection with a serious crime;
  • required by law, regulation, or regulatory authority;
  • we reasonably believe that you have engaged in conduct involving the commission of an offence in the course of providing goods or services to a third party, and a payment service under this agreement has been used in connection with that conduct.

Where there is a conflict between any notice or termination requirement and another legal obligation binding on us, the other legal obligation prevails to the extent of the conflict.

10.3. Termination by You

You may terminate this agreement at any time by giving us written notice using the contact details in Section 2.2. Unless we have agreed a specific notice period with you in writing, no minimum notice period applies and you may terminate with immediate effect.

Where we have agreed a notice period, that period will not exceed one month.

We will not charge you for terminating this agreement after the first six months from the date it commenced. If you terminate within the first six months, any charge applied will reasonably correspond to our actual costs of termination and will not exceed those costs.

10.4. Effect of Termination

Upon termination:

  • access to services will be revoked;
  • pending transactions may be cancelled or completed at the Company’s discretion;
  • the Company may retain information as required by law.

Termination shall not affect:

  • accrued rights and obligations;
  • any provisions intended to survive termination.

11. Record Keeping

We will retain all records for a minimum of five years from the date each record was created, in a form that enables the FCA to supervise our compliance effectively.

This includes records of client onboarding and verification, payment instructions and their execution, transaction data, complaints, and material correspondence with regulators.

Where records contain your personal data, they are retained in accordance with our Privacy Policy and our obligations under the UK General Data Protection Regulation and the Data Protection Act 2018. Records will continue to be held following termination of our relationship for the remainder of the applicable retention period.

12. Glossary

Authorised Payment Institution

A party authorised by the FCA to provide payment services under the Payment Services Regulations 2017.

Business Day

Any day on which the Company is open for business as required for the execution of a payment transaction — Monday to Friday, excluding UK public holidays.

Customer Due Diligence

The identification, verification and ongoing monitoring measures required under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The Company may refuse or terminate services if it is unable to complete customer due diligence.

Cut-off Time

The daily deadline for same-day processing of payment orders, set at 15:00 UK time on business days (Monday to Friday, excluding UK public holidays). Payment orders received after the cut-off time or on a non-business day are treated as received on the next business day.

Durable Medium

Any instrument which enables the Client to store information addressed personally to them in a way accessible for future reference for a period of time adequate for the purposes of the information and which allows the unchanged reproduction of that information; for example, email or a downloadable document.

Enhanced Due Diligence

Additional verification and monitoring measures applied where a client is identified as high risk, including politically exposed persons or clients with connections to high-risk jurisdictions or sectors. Enhanced due diligence may be imposed as a condition of service.

Money Laundering Regulations

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692), which impose customer due diligence, record-keeping and other anti-money-laundering obligations on the Company.

Money Remittance

The service of receiving funds from the Client and transmitting them to a payee or another payment service provider on the Client’s behalf, without the Company maintaining a payment account in the Client’s name.

Payee

The intended recipient of funds which have been the subject of a payment transaction; the party to whom the Company transmits funds on the Client’s behalf in a money remittance.

Payer

A person who holds a payment account and initiates, or consents to the initiation of, a payment order from that account; or, where there is no payment account, a person who gives a payment order.

Payment Account

An account held in the name of one or more payment service users used for the execution of payment transactions. The Company does not maintain payment accounts for clients or hold funds on an ongoing basis.

Payment Order

Any instruction given by the Client to the Company requesting the execution of a payment transaction. A future-dated payment order becomes irrevocable at 09:00 am on the scheduled execution date.

Payment Service Provider

Any entity providing payment services, including authorised payment institutions, small payment institutions, electronic money institutions and credit institutions. Used in these Terms to refer to the Company and its regulated third-party partners.

Payment Services

The service of initiating payment orders from a payment account held with another provider, at the Client’s request. The Company’s registered permissions are limited to money remittance and payment services within the United Kingdom.

Payment Services Regulations 2017

The Payment Services Regulations 2017 (SI 2017/752), the principal UK legislation transposing the EU Payment Services Directive (PSD2) and governing the regulation of payment services in the United Kingdom, under which the Company operates as a Small Payment Institution.

Payment Transaction

An act of placing, transferring or withdrawing funds, initiated by or on behalf of the payer, irrespective of any underlying obligations between the payer and payee. The Company’s total payment transaction volume is subject to a monthly cap of £3 million on average.

Personalised Security Credentials

Login passwords, one-time passcodes and any other security information provided by the Company to the Client for the purpose of accessing the Company’s services or authenticating a payment instruction. The Client must keep these safe and confidential at all times.

Politically Exposed Persons

Individuals who hold, or have held, prominent public positions, together with their family members and known close associates. The Company may apply enhanced due diligence to clients who are, or are connected to, politically exposed persons.

Pricing Agreement

The individual agreement between the Company and the Client setting out all charges, fees, FX margins and rates applicable to the Client’s account. The Pricing Agreement is disclosed, agreed and signed before services begin and forms part of the Client’s agreement with the Company.

Risk Appetite Policy

The Company’s internal policy defining the categories of client, transaction, jurisdiction and business activity that the Company will and will not service. The Company may refuse, restrict or terminate services where the Client falls outside the Risk Appetite Policy.

Safeguarding

The regulatory obligation to keep client funds strictly separate from the Company’s own funds and to hold them in a dedicated safeguarding account with an FCA/PRA-authorised bank, ensuring they are ringfenced and protected from the claims of the Company’s creditors in the event of insolvency.

Small Payment Institution

A payment service provider registered (not authorised) by the FCA under the Payment Services Regulations 2017 whose total payment transaction volume does not exceed £3 million on average per month, calculated over the preceding 12 months across all payment services provided.

Strong Customer Authentication

Authentication based on two or more independent elements drawn from: something known only by the payment service user (knowledge); something held only by the payment service user (possession); something inherent to the payment service user (inherence). The Company is liable for unauthorised transactions where it failed to apply strong customer authentication where required.

Tipping-off

The criminal offence under the Proceeds of Crime Act 2002 or the Terrorism Act 2000 of disclosing information that might prejudice an investigation. The Company may be unable to give reasons for a refusal or termination where doing so would constitute a tipping-off offence.

Ultimate Beneficial Owners (UBOs)

Any natural person who directly or indirectly owns or controls more than 25% of the Client’s shares or voting rights, or who otherwise exercises control over the management of the Client’s organisation. The Client must identify and verify all UBOs as part of onboarding.

Unique Identifier

The combination of identifying information that the Client must provide to initiate a payment instruction: for UK GBP transfers, the payee’s legal name, sort code (6 digits) and account number (8 digits); for international transfers, the payee’s legal name, IBAN and BIC/SWIFT code. The Company executes payment instructions based on the unique identifier provided and is not liable for non-execution arising from an incorrect unique identifier.

Value Date

A reference time used by a payment service provider for the calculation of interest on funds debited from or credited to a payment account. Monthly statements include the debit or credit value date for each transaction.