Safeguarding Information

1. What safeguarding means

In this document, safeguarding means the operational, accounting, banking and governance arrangements used to identify, control and protect money received from customers for a specific transfer or foreign-exchange transaction.

The aim is to prevent customer transaction funds from being treated as ordinary Kingscross operating income and to maintain records showing what Kingscross owes to customers, beneficiaries, banks and payment partners.

2. Funds intended to be covered

The safeguarding framework is intended to apply to cleared funds received and accepted by Kingscross for:

• money-transfer transactions;
• foreign-exchange transactions;
• payments awaiting conversion or onward settlement;
• refunds awaiting return to the verified customer;
• other customer payment obligations approved as part of the service.

A payment is not treated as fully received merely because a customer has initiated it. Funds must be credited, identified and successfully matched to the relevant transaction.

3. Amounts that may not be treated as customer transaction funds

Depending on the final legal and accounting structure, the following may not remain part of the customer-funds balance after they are properly due or paid:

• a disclosed Kingscross fee that has been earned;
• an exchange-rate margin already realised through a completed conversion;
• a tax, levy or charge payable to a public authority;
• a third-party charge already paid or irrevocably incurred;
• funds already delivered to the beneficiary or settlement destination;
• company capital or operating money.

The final treatment must follow the approved accounting policy, banking arrangements, licence requirements and applicable law.

4. How customer funds may be received

Kingscross may receive customer funds through approved channels such as:

• bank transfer;
• Paybill or approved mobile-money collection;
• approved card or payment collection service;
• an authorised Kingscross branch;
• an approved agent, where permitted and properly controlled;
• another channel expressly displayed in the transaction instructions.

Customers must not send funds to an employee’s, director’s, agent’s or representative’s personal account or private wallet.

5. Separation from Kingscross operating funds

Customer transaction funds should be received into or promptly transferred to approved accounts used for customer collections and settlement rather than ordinary day-to-day company expenditure.

Kingscross operating expenses—including salaries, rent, marketing, technology and general administration—should be paid from separate company operating accounts.

Transfers between customer-funds and operating accounts should be limited to properly identified amounts, such as earned fees, approved corrections or authorised settlement movements, and should be supported by records and approval.

6. Approved bank and collection accounts

Kingscross should maintain an approved register of bank, Paybill, mobile-money, settlement and collection accounts used in the customer-funds process.

The register should identify:

• the financial institution or service provider;
• the account name and purpose;
• the currencies supported;
• authorised users and approval limits;
• reconciliation responsibility;
• the status of the account;
• any contractual restriction or security arrangement.

Only approved account details should be shown to customers.

7. Transaction references and payment matching

Each transaction should receive a unique reference. Customers must use that reference when funding the transaction.

Kingscross should match incoming funds using information such as:

• transaction or quote reference;
• customer name;
• funding-account name;
• amount and currency;
• date and time;
• bank, Paybill or payment-provider confirmation.

A transaction may be delayed until the payment is identified and reconciled.

8. Reconciliation of customer funds

Kingscross should regularly compare its customer obligations with the money held or controlled through approved collection, settlement and payout arrangements.

Reconciliation should include, where relevant:

• opening and closing bank balances;
• customer funds received;
• unmatched incoming payments;
• transactions awaiting conversion;
• transactions awaiting payout or settlement;
• completed settlements;
• failed and returned transactions;
• refunds payable;
• fees and deductions;
• bank and partner balances;
• identified differences or shortfalls.

Material differences should be investigated promptly and escalated under the approved incident and financial-control procedures.

9. Customer-funds records

Kingscross should maintain records that allow each material movement of customer funds to be traced from receipt through conversion, settlement, payout, refund or return.

Records may include:

• customer and beneficiary information;
• transaction and quote references;
• funding confirmations;
• exchange rates and fees;
• settlement instructions;
• bank and partner reports;
• reconciliation records;
• approval and audit logs;
• refund and exception records.

10. Access, approval and segregation of duties

Access to customer-funds systems and accounts should be restricted according to job responsibility and reviewed periodically.

Controls should include, where appropriate:

• role-based access;
• multi-factor authentication;
• maker-checker or dual approval;
• transaction and user limits;
• segregation between initiation, approval and reconciliation;
• audit logging;
• periodic access review;
• prompt removal of access when responsibilities change.

11. Conversion, settlement and payout

Customer funds may be converted, transferred or made available through approved banks, payment networks, mobile-money operators, card systems or payout partners.

The customer-funds records should be updated as the transaction moves through each stage. A transaction should not be marked completed solely because Kingscross sent an instruction; completion should reflect the status received from the relevant settlement or payout process.

12. Banks, collection providers and payment partners

Kingscross may depend on regulated banks and approved payment partners to collect, hold, convert, transmit or pay funds.

Before appointment, Kingscross should assess relevant matters such as:

• legal and regulatory status;
• financial and operational capacity;
• customer-funds and settlement arrangements;
• information security;
• business continuity;
• reconciliation and reporting;
• contractual rights and responsibilities;
• concentration and exit risk.

Use of a partner does not eliminate all counterparty, banking, operational or country risk.

13. Liquidity, prefunding and settlement balances

Kingscross may need to maintain prefunded or settlement balances with approved partners to support timely payout and foreign-exchange execution.

Liquidity levels should be monitored against expected transaction volume, settlement cycles, currency needs, partner cut-off times, refunds and stress scenarios.

Customer funds should not be used for speculative trading or unrelated lending.

14. Delayed transactions

A transaction may be delayed because of:

• late or unmatched funding;
• incomplete KYC or source-of-funds information;
• fraud or sanctions review;
• banking or payment-system outages;
• partner cut-off times;
• currency liquidity constraints;
• incorrect beneficiary details;
• legal or regulatory restrictions.

During a delay, Kingscross should maintain an identifiable record of the relevant customer obligation and provide a status update where lawful and reasonably possible.

15. Failed, rejected or cancelled transactions

If a transaction cannot proceed, Kingscross should determine whether the funds can be:

• reprocessed following correction;
• requoted with customer agreement;
• returned to the original verified funding source;
• held temporarily where required by law or compliance controls.

A transaction may remain unresolved while Kingscross awaits information from a bank, partner, customer, beneficiary or competent authority.

16. Refunds and returned customer funds

Refunds should normally be returned to the original verified funding source. Another method should be used only where lawful, verified and appropriately approved.

The refundable amount may be affected by:

• completed currency conversion;
• exchange-rate movements;
• bank or partner return charges;
• funds already delivered or irreversibly transmitted;
• lawful fees or deductions disclosed under the Terms and Conditions.

Kingscross should provide an explanation of deductions it controls.

17. Unmatched and unidentified funds

Incoming money that cannot be matched to a customer or transaction should be recorded separately and investigated.

Kingscross may request proof of payment, bank statements, account ownership, transaction purpose or other evidence before allocating or returning unmatched funds.

Unmatched money should not be treated as company income merely because the payer has not yet been identified.

18. Compliance and legal holds

Kingscross may be required to delay, freeze, reject, return or otherwise restrict funds because of sanctions, AML, fraud, court, regulator, law-enforcement or partner requirements.

In some circumstances, Kingscross may not be legally permitted to disclose the existence or full reason for a hold, report or investigation.

A compliance hold does not mean that Kingscross may use the money for operating purposes.

19. Interest and investment of customer funds

Customer transaction funds are held for payment and settlement purposes, not as a savings or investment product.

Unless expressly required by law or agreed in a separate approved product, customers are not entitled to interest or investment return on money awaiting conversion, settlement, payout or refund.

Kingscross should not place customer transaction funds into speculative or high-risk investments.

20. Insolvency and legal limitations

Separating and reconciling customer transaction funds is intended to improve identification and protection if Kingscross experiences financial distress. However, the actual legal treatment of funds in insolvency depends on applicable law, account structure, contractual terms, bank records and the circumstances at the time.

Kingscross must not represent that every customer will automatically or immediately recover the full amount in every insolvency or bank-failure scenario.

21. Safeguarding is not deposit insurance

22. Monitoring, assurance and oversight

The customer-funds framework should be supported by:

• daily or appropriately frequent reconciliations;
• management review of exceptions;
• finance and compliance oversight;
• internal control testing;
• independent audit or assurance where required;
• Board or committee reporting;
• regulatory reporting and inspection where applicable;
• corrective-action tracking.

23. Shortfalls, incidents and corrective action

If Kingscross identifies a customer-funds shortfall, unexplained difference, bank error, partner failure or unauthorised movement, it should:

1. record and investigate the incident;
2. protect available funds and evidence;
3. stop further unauthorised activity where possible;
4. escalate to management, compliance and the Board as appropriate;
5. correct the records or fund the shortfall where required and lawful;
6. notify the relevant bank, partner, insurer or authority where required;
7. identify root cause and implement corrective action.

24. Business continuity and system disruption

Kingscross should maintain continuity and recovery arrangements for customer-funds records, payment instructions, reconciliations and critical banking or partner communications.

During a system disruption, Kingscross may temporarily restrict new transactions while preserving records and prioritising in-flight payments and customer-funds reconciliation.

25. Customer precautions

Customers can help protect their funds by:

• using only account and Paybill details shown through approved Kingscross channels;
• using the exact transaction or quote reference;
• funding from an account held in their own or authorised business name;
• checking the beneficiary details before confirming;
• keeping receipts and payment confirmations;
• reporting an incorrect payment, fraud concern or missing transaction immediately;
• never paying an employee or agent through a personal account or wallet.

26. Questions, tracing requests and complaints

A customer who believes funds have not been properly received, matched, settled, paid or refunded should provide:

• their name and contact details;
• transaction or quote reference;
• amount, currency and date;
• funding-account or Paybill information;
• proof of payment;
• beneficiary or settlement details.

Kingscross should investigate under its transaction-tracing, reconciliation and Complaints Procedure.

27. Customer-funds control summary

28. Contact details