MEMA Scope · Assessment
Do money transfer and remittance businesses need FCA authorisation?
A business receives money from customers to transfer to a person or account elsewhere without opening payment accounts for them. Review the initial view below and answer a few questions to refine it.
- Personalised to your business
- FCA rule references
- Follow-up questions available
Potential regulated activity identified
Money remittance may require authorisation or registration
Money remittance is a payment service. Authorisation or small payment institution registration is needed unless you are an agent of a regulated firm.
Route to consider: Direct authorisation (full permission)
Why this was flagged
- 1Receiving funds from a payer solely to transfer them to a payee is money remittance, a payment service.
- 2Cross-border transfers are common in this model and bring financial crime risks.
Questions still to resolve
Answer to refine the view. The result updates as you go.
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Will your average monthly transfer volume stay at or below EUR 3m?
- ?
Do you only move your own money, for your own business purposes, and not customers’ money?
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Will you act as an agent of a regulated money transfer firm?
Regulatory basis to examine
Your next steps
- 1Map your corridors, partners and where funds are held
- 2Decide between authorisation, small payment institution registration and agent status
- 3Document sanctions screening and AML controls
- 4Design safeguarding arrangements
Where applications for this model most often fall short
- Sanctions and AML controls evidence
- Partner bank and correspondent arrangements
- Safeguarding and reconciliation process
This is an initial indication from published FCA material, not an FCA determination or legal advice.
If authorisation is required, check the firm’s governance, policies, resources and application preparedness.
MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.
About this business model
A business receives money from customers to transfer to a person or account elsewhere without opening payment accounts for them.
Money remittance is a payment service. Authorisation or small payment institution registration is needed unless you are an agent of a regulated firm.
This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.
Money transfer or remittance business: frequently asked questions
Does a money transfer business need FCA registration?
Money remittance is a payment service under the PSRs. Businesses need authorisation or registration as a payment institution, or to be registered agents of one.
How much can a small payment institution transfer?
The small payment institution route is for firms with an average monthly payment volume of no more than EUR 3m.
What could change the answer for money transfer and remittance businesses?
Money remittance is a payment service. Authorisation or small payment institution registration is needed unless you are an agent of a regulated firm. It can change depending on the answers to questions such as: Will your average monthly transfer volume stay at or below EUR 3m? Do you only move your own money, for your own business purposes, and not customers’ money? Will you act as an agent of a regulated money transfer firm?
Which FCA rules should money transfer and remittance businesses look at first?
Start with: Money remittance and payment services; Perimeter guidance on the PSRs; FCA: payment institution applicants. This is an initial view from published FCA material, not an FCA determination.
What are the first steps for money transfer and remittance businesses?
Map your corridors, partners and where funds are held. Decide between authorisation, small payment institution registration and agent status. Document sanctions screening and AML controls. Design safeguarding arrangements.
Businesses we check
MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.
Consumer credit
- Do car dealers offering finance need FCA authorisation?
- Do motor finance brokers need FCA authorisation?
- Do retailers offering buy now pay later need FCA authorisation?
- Do consumer lenders need FCA authorisation?
- Do debt collectors and debt administrators need FCA authorisation?
- Do debt management and debt advice firms need FCA authorisation?
- Do credit lead generators and comparison sites need FCA authorisation?
- Do rent-to-own and vehicle leasing providers need FCA authorisation?
- Do credit brokers introducing customers to lenders need FCA authorisation?
Payments and e-money
- Do payments apps and payment processors need FCA authorisation?
- Do small payment institutions need FCA authorisation?
- Do e-money issuers and digital wallets need FCA authorisation?
- Do agents of payment institutions need FCA authorisation?
- Do open banking providers need FCA authorisation?
- Do marketplaces handling payments need FCA authorisation?
Insurance
Mortgages
Investments and wealth
- Do financial advisers need FCA authorisation?
- Do discretionary investment managers need FCA authorisation?
- Do investment platforms and wealth-tech firms need FCA authorisation?
- Do crowdfunding and peer-to-peer lending platforms need FCA authorisation?
- Do corporate finance boutiques need FCA authorisation?
Other regulated activities
- Do claims management companies need FCA authorisation?
- Do funeral plan providers and sellers need FCA authorisation?
- Do introducers and referral partners need FCA authorisation?
- Do international firms entering the UK need FCA authorisation?
- Do accountants and solicitors giving financial advice need FCA authorisation?
Want a consultant to look at your facts?
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