Terms and Conditions

Framework Agreement

Moneliq Limited (Company Number: 12213334) is a company registered in England and Wales, with its registered office at 25 Cabot Square, London, England, E14 4QZ.

Moneliq Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Electronic Money Institution under the Electronic Money Regulations 2011. Our FCA Firm Reference Number (“FRN”) is 901056.

You can verify our regulatory status by visiting the  FCA Register and searching for “Moneliq Limited” or by using our Firm Reference Number (FRN) 901056.

This Agreement is entered into for the Provision of Electronic Money, Payment Acquisition, Money Remittance, and Open Banking Services (AIS/PIS).

  1. Definitions and Interpretation

"Agreement": This framework and its schedules/annexes.

 

"Customer": The client contracting with Moneliq for one or more services under this Agreement.

 

"Services": E-Money issuance/redeeming, payment acquiring, money remittance, AIS, PIS (as described in Schedule 1).

 

"Open Banking": Access to AIS and PIS under the Payment Services Regulations 2017 (SI 2017/752).

 

"Acquirer" "Merchant" "Sub-Client" and other stakeholder terms use definitions as per all forms​ accompanied.

 

Interpretations, subdivision precedence, and other legal construction terms as set out in the attached agreements.​

  1. Scope of Services/Provision of Services

Moneliq will provide the Customer with one or more of the following, in the UK and EU:

 

E-Money Issue & Redemption: Issue, store, redeem electronic money in compliance with UK EMRs​. Important: Electronic money issued by Moneliq is not a deposit and is not protected by the Financial Services Compensation Scheme. Customer funds are safeguarded in compliance with the Electronic Money Regulations 2011 but will not benefit from FSCS protection.

 

Acquiring Services: Enable merchant acceptance and processing of payment transactions (cards or alternative methods)​.

 

Money Remittance: Facilitate payment orders and funds remittance for and on behalf of Customer.

 

Open Banking (AIS/PIS): Provide access to Account Information Services and Payment Initiation Services through Moneliq or as agent of a regulated provider.

 

Sub-clients: Where agreed, Moneliq may enable Customer’s connected sub-clients to utilise the Services, subject to due diligence and ongoing compliance oversight​.

 

  • 2.1 In consideration of payment by the Merchant of the Charges and Fees, Moneliq agrees, subject to the terms and conditions of the Agreement, to provide the Merchant with the Services as initially selected in the Application Documentation and amended, updated, supplemented and/or replaced from time to time in accordance with the Agreement. The Merchant can ask Moneliq for a copy of the Agreement at any time.

 

  • 2.2 Moneliq may from time to time provide the Merchant with Additional Services. Each Additional Service will be governed by the Additional Service Conditions applicable to it as well as the other terms and conditions of the Agreement. The Additional Service Conditions will be provided to the Merchant as and when they are applicable to the Merchant and the Agreement. The Merchant must pay the Charges and Fees (plus VAT, where applicable) relating to any Additional Service in accordance with the applicable Additional Service Conditions and the other parts of the Agreement.

 

  • 2.3 If the Merchant requires any additional product and/or service from Moneliq, which is not offered by Moneliq in the form of an Additional Service or other element of the Services, the Merchant shall issue a written request to Moneliq and, where Moneliq is willing to provide the relevant product and/or service, Moneliq shall propose a separate written agreement setting out the terms and conditions on which it is willing to provide such product and/or service ("Separate Agreement"). Unless and until such time as a Separate Agreement has been agreed and signed by or on behalf of the parties to govern Moneliq's provision of any additional product and/or service requested by the Merchant, Moneliq shall not be under any obligation to provide the relevant product and/or service. Once agreed and signed by or on behalf of the parties, each Separate Agreement will be entirely independent and separate from the Agreement.

 

  • 2.4 Consumer Protection and FSCS Disclosure

 

  • Moneliq is authorised by the Financial Conduct Authority (FCA) as an Electronic Money Institution. Funds held with Moneliq in connection with your e-money account, acquiring services, money remittance, or open banking activities are not deposits and do not earn interest. Your funds are not covered by the Financial Services Compensation Scheme (FSCS).

 

  • However, in accordance with the FCA’s safeguarding requirements, we protect your money by placing it into segregated safeguarding accounts with regulated credit institutions. This ensures that your funds remain separate from Moneliq’s own funds and are protected in the event of our insolvency.
  1. Term and Termination

This Agreement is effective from the date of execution, for an indefinite term, subject to initial/renewal periods as set out in the relevant Service Schedules.

 

Either party may terminate on not less than 2 months’ written notice (for ongoing services) or as per specific event/cause as detailed in attached forms (e.g. breach, insolvency, regulatory risk, or account inactivity).​

 

Moneliq may terminate or suspend some or all services immediately upon regulatory breach, security incident, non-payment, change to prohibited business, or where required by applicable law.

 

Change Control and Variation Process:

 

Moneliq may amend the terms of this Agreement, including changes to the services we provide, operational processes, or pricing, to reflect legal, regulatory, or business requirements.

 

We will provide you with at least 60 days’ written notice before any change takes effect, unless a shorter period is required by law or is necessary to address fraud prevention, security, or compliance matters. The updated terms will be made available on our website and, where applicable, communicated through your registered email or customer dashboard.

 

If you do not agree to the changes, you may terminate this Agreement free of charge before the effective date of the changes. Your continued use of our services after the effective date will constitute acceptance of the revised terms.

 

Any changes that do not affect your rights or obligations materially, such as minor editorial or administrative updates, may be made without prior notice but will be published promptly on our website.

  1. Fees and Payment

Fees, minimum monthly commitments, and tariffs for each Service are set out in the applicable Schedule(s) or Service Order Forms. Fees may include set-up, monthly, per-transaction, and volume-based charges.

 

Additional fees (e.g., chargebacks, card scheme penalties, investigation costs, reserves/rolling reserve, chargeback fees, fraud screening) may be applied as outlined.

 

Moneliq will invoice for Services in accordance with the agreed billing terms. All invoices must be paid within thirty (30) days of the invoice date. Interest on overdue amounts shall accrue at the rate specified in this Agreement or, if not stated, at the statutory rate under the Late Payment of Commercial Debts (Interest) Act 1998.

 

You may request redemption of your e-money balance at any time, subject to Moneliq’s published redemption procedures and any applicable fees set out in the relevant Service Schedule. Redemption requests will be processed promptly and no later than the end of the business day following receipt, unless further information is required to comply with legal or regulatory obligations.

  1. Service Obligations & Limitations

Customer must comply with all applicable laws, provide accurate information, maintain valid authorisations and licenses, and not use services for unlawful or restricted activities.

 

Moneliq reserves the right to:

 

Review and adjust its Fees or pricing structure at any time, by providing not less than sixty (60) days' written notice to the Customer.

 

Deduct or offset any unpaid or disputed sums, chargebacks, penalties, or other liabilities arising under this Agreement from settlement or payout amounts due to the Customer.

 

Require pre-funding, security deposits, or reserves (including rolling or capped reserves) where Moneliq reasonably determines that increased risk, exposure, or non-compliance may exist.

 

Suspend or withhold the settlement of funds in the event of suspected fraud, chargeback activity, a regulatory investigation, or a breach of any applicable regulatory, card network, or scheme rules.

 

All fees and charges are exclusive of VAT and any other applicable taxes, which shall be payable by the Customer in addition to the quoted amounts.

 

The Customer must comply with all applicable laws, regulations, and regulatory guidance, including but not limited to the Financial Services and Markets Act 2000, the Electronic Money Regulations 2011 (EMR), the Payment Services Regulations 2017 (PSR), the Data Protection Act 2018, the UK GDPR, and guidance issued by the FCA and relevant card schemes. The Customer shall provide accurate, complete, and up-to-date information to Moneliq at all times, maintain valid authorisations, licences, and approvals, and ensure that its business activities are lawful and properly disclosed. Services must not be used for any prohibited, unlawful, or restricted purposes as defined by Moneliq’s Acceptable Use Policy or relevant regulatory standards.

 

Acquiring and Card Acceptance Obligations

For the provision of card acquiring and acceptance services, the Customer must:

 

Adhere at all times to all applicable card scheme rules, network operating regulations, and any technical standards mandated by other scheme partners.

 

Not exceed published or permitted thresholds for chargebacks, fraud, or excessive refund activity.

 

Maintain appropriate fraud prevention, transaction validation, and dispute management controls.

 

Display scheme marks, acceptance logos, and required disclosures in accordance with card scheme and Moneliq branding requirements.

 

Maintain PCI DSS compliance and security of cardholder data, including not storing or transmitting sensitive authentication data except as permitted by scheme standards.

 

Notify Moneliq immediately of any suspected data breach, compromise, or unauthorised transaction activity.

 

Refrain from surcharge practices or transaction routing that breach scheme or legal requirements.

 

E-Money Services

For E-Money accounts and issuance:

 

The Customer acknowledges that all client funds are safeguarded in accordance with Regulation 20 of the EMR and are segregated from Moneliq’s own funds.

 

Funds held as e-money are not deposits and are not covered by the Financial Services Compensation Scheme (FSCS).

 

Interest or equivalent benefits are not payable on e-money balances.

 

The Customer retains a redemption right in accordance with the EMR, subject to Moneliq’s applicable redemption procedures, fees, and timeframes.

 

Any misuse of the e-money platform or breach of AML/CTF rules may result in immediate suspension or termination of the service.

 

Open Banking Services

For access to Open Banking services:

 

The Customer must obtain and maintain all consents and permissions from its users required under the PSR, FCA rules, and Moneliq’s technical and data sharing agreements.

 

Data access and processing must be clear, informed, and transparent, with user consent recorded and maintained.

 

All personal data processing must be conducted in full compliance with the Data Protection Act 2018, UK GDPR, and Moneliq’s Data Processing Agreement (DPA) and associated addendums.

 

The Customer must not misuse, retain, or share account information beyond the purpose authorised by the account holder or allowed by Moneliq.

 

Any data subject or withdrawal of consent notices must be communicated promptly to Moneliq.

 

Remittance and Cross-Border Payments

For remittance and money transfer services:

 

The Customer must comply with all AML/CTF obligations under the Money Laundering Regulations 2017 (as amended), including appropriate KYC and ongoing transaction monitoring.

 

The Customer must not process payments for sanctioned individuals or jurisdictions listed under UK, EU, OFAC, or UN sanctions lists.

 

All originator and beneficiary information must be accurate, traceable, and retained in accordance with FATF Recommendation 16 and UK requirements on wire transfers.

 

The Customer accepts that Moneliq may delay, suspend, or refuse transactions where required to comply with legal, regulatory, or risk management obligations.

 

General Limitations and Rights

Moneliq may:

 

Amend or withdraw any service in response to regulatory, scheme, or partner requirements, providing reasonable notice where practicable.

 

Suspend services, settlements, or account access if risk levels, breaches, or investigations arise.

 

Require enhanced due diligence (EDD), security deposits, or adjusted transaction limits based on risk profiling.

 

Share information with regulators, law enforcement, and scheme partners as required under applicable laws and regulatory obligations.

 

The Customer remains fully responsible for all acts, omissions, and compliance of its employees, agents, and sub-merchants (where applicable) in connection with the use of the Services.

 

  • 5A.2 Eligibility
  • The APP reimbursement provisions apply to Customers and End Users who meet the eligibility criteria under the applicable APP reimbursement rules (including consumers, micro‑enterprises and charities within the relevant thresholds).

 

  • A claim must relate to one or more In‑Scope Payment Systems payments made on or after 7 October 2024 and must be raised no later than 13 months after the date of the last payment made as part of the same scam.

 

  • 5A.3 Reimbursement and limits
  • Subject to clauses 5A.4 and 5A.5, where an eligible Customer or End User has fallen victim to an APP Scam in relation to an In‑Scope Payment Systems payment, Moneliq (acting as sending payment service provider) will reimburse the Customer for the Reimbursable Amount in accordance with the mandatory requirements set by the Payment Systems Regulator.

 

  • The Reimbursable Amount for any single APP Scam is subject to the maximum reimbursement cap in force under the APP reimbursement rules (currently £85,000 per claim, including all related payments that form part of the same scam) and any permitted excess which Moneliq may apply (currently £100 per claim).

 

  • Moneliq will normally make reimbursement within five Business Days of determining that the claim is in scope, subject to any permitted “stop‑the‑clock” pauses where additional information or co‑operation is required.

 

  • 5A.4 Customer standard of caution and co‑operation
  • To be eligible for reimbursement, the Customer and any End User must:
    • (a) take reasonable steps to protect themselves from scams, including reading and acting on any warnings presented in Moneliq’s channels at or before the time of payment;
    • (b) carry out basic checks where prompted (for example, contacting the payee using trusted contact details, and considering whether the payment request is consistent with their usual dealings); and
    • (c) report suspected APP Scams to Moneliq as soon as reasonably practicable and, in any event, within 13 months of the last payment related to the scam, and respond truthfully and promptly to Moneliq’s reasonable information requests.

 

  • Moneliq will have regard to FCA expectations and the Consumer Duty when assessing whether the Customer has met the required standard of caution, particularly where vulnerability may have had a material impact on their ability to protect themselves.

 

  • 5A.5 Exceptions to reimbursement
  • Moneliq may decline reimbursement where:
    • (a) the Customer or End User has acted fraudulently (first‑party fraud); or
    • (b) the Customer or End User has acted with gross negligence in failing to meet the standard of caution set out in clause 5A.4, taking into account applicable regulatory rules and guidance; or
    • (c) the payment is outside the scope of the APP reimbursement rules (including, without limitation, payments executed before 7 October 2024, payments outside the In‑Scope Payment Systems, or payments to an account owned or controlled by the Customer).

 

  • Moneliq will not treat a Customer as grossly negligent solely because they have fallen victim to a sophisticated scam. Moneliq will assess each case individually, considering all relevant evidence and any indicators of vulnerability.

 

  • 5A.6 Receiving‑PSP and “on‑us” payments
  • Where Moneliq acts as receiving payment service provider in relation to an APP Scam, Moneliq will meet any contribution obligations owed to the sending payment service provider under the applicable APP reimbursement rules.

 

  • Where both the sending and receiving accounts are held with Moneliq (“on‑us” payments), Moneliq will apply protections that are at least equivalent to those that would apply if the payment were executed over an In‑Scope Payment System, subject to any differences permitted under applicable regulation and guidance.

 

  • 5A.7 Process and complaints
  • Customers can raise an APP Scam claim using the usual incident reporting channels set out in Clause 14 and may submit a complaint under Clause 11 if dissatisfied with the handling or outcome of a claim.

 

  • If the Customer remains dissatisfied and is an eligible complainant, the Customer may refer the matter to the Financial Ombudsman Service in accordance with Clause 11.
  1. Due Diligence, AML, Sub-Clients

Moneliq (and, where applicable, its regulated partners will perform all necessary Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and sanctions screening checks on all Customers and, where applicable, on any of their sub-clients or associated entities. The Customer acknowledges that services are conditional upon successful completion of these checks, and Moneliq reserves the right to decline, restrict, or terminate services where onboarding requirements are not met or where ongoing monitoring identifies material risk.

 

The Customer shall fully cooperate with Moneliq and its partners in providing information, documentation, and evidence as requested at any stage for initial verification or ongoing monitoring, including but not limited to:

 

Corporate and ownership documentation identifying ultimate beneficial owners (UBOs).

 

Details of directors, controllers, and authorised representatives.

 

Proof of business activities, source of funds, and expected transaction volumes and counterparties.

 

Periodic reviews, sanctions and PEP (Politically Exposed Person) screening confirmations.

 

Transaction-level information requested for investigations or suspicious activity reviews.

Failure to provide accurate or timely information constitutes a material breach of this Agreement and may result in service suspension, delayed settlement, or termination as deemed necessary by Moneliq.

 

Customer Due Diligence and Sub-Client Responsibilities

Where the Customer introduces, onboards, or processes transactions for third parties (“sub-clients”, “merchants”, or “end users”), the Customer is solely responsible for performing adequate due diligence and risk assessment on each such sub-client and maintaining full visibility and control over their activities. The Customer must:

 

Implement and maintain AML, CTF, and sanctions policies, systems, and controls proportionate to its business and risk profile.

 

Identify and verify each sub-client’s legal identity, ownership, and business nature before permitting access to any payment, e-money, or acquiring service.

 

Conduct ongoing monitoring of sub-clients’ transactions, ensuring continuous compliance with AML and fraud prevention standards.

 

Ensure sub-clients do not use the services for illegal, high-risk, or prohibited activities as defined under Moneliq’s Acceptable Use Policy and applicable FCA/AML rules.

 

Retain records of all KYC and transactional information for a minimum of five (5) years or longer where required by law.

 

Immediately report to Moneliq any suspicious, unusual, or high-risk activity and cooperate with requests for supporting documentation or data.

 

Monitoring, Reporting, and Cooperation

Moneliq and its regulated partners will perform ongoing transaction monitoring, sanctions checks, and screening of all transactional activity to detect, prevent, and report suspicious transactions in line with the Money Laundering Regulations 2017 (as amended) and FCA supervisory expectations. The Customer acknowledges and agrees that:

 

Moneliq may delay, freeze, or decline transactions where enhanced due diligence or investigation is required.

 

Certain information may be disclosed to regulatory or law enforcement authorities where required under applicable laws.

 

Moneliq may impose enhanced due diligence (EDD), limit transactions, or adjust settlement timing for higher-risk customers or sub-clients.

 

Any failure to respond to AML, sanctions, or fraud-related information requests within the specified timeframe may result in the immediate suspension or termination of services.

 

Audit and Verification Rights

Moneliq reserves the right to audit or review the Customer’s AML and compliance procedures, either directly or through appointed representatives, at reasonable intervals. Such reviews may include inspection of KYC records, monitoring reports, and control procedures relating to sub-clients. The Customer shall grant timely access to all requested materials and cooperate fully with any audit process.

 

Where deficiencies or policy breaches are identified, Moneliq may issue remediation requirements that must be completed within a specified period. Failure to remedy such issues constitutes a material breach of this Agreement and may lead to service suspension or termination.

 

The parties acknowledge that Moneliq remains ultimately responsible for maintaining compliance with regulatory obligations under the EMR, PSR, and MLR, and that cooperation with its due diligence and oversight functions is a strict condition of continued service provision.​

  1. Liability and Indemnity

Each party’s liability under this Agreement is subject to the exclusions and limitations of liability set out within this clause and, where applicable, within the individual Service Schedules or Order Forms. Liability provisions apply collectively across all Services provided by Moneliq and its regulated partners, including (without limitation) acquiring, e-money, Open Banking, and remittance services.

 

Exclusions and Non-Limited Liabilities

Nothing in this Agreement excludes or limits either party’s liability for:

 

Death or personal injury caused by its negligence or that of its employees or agents.

 

Fraud, fraudulent misrepresentation, or wilful misconduct.

 

Breach of any regulatory obligation or indemnity provided under this Agreement.

 

Any other liability that cannot lawfully be excluded or limited under applicable law.

 

Except as set out above, Moneliq shall not be liable for:

 

Any indirect, special, incidental, punitive, or consequential loss;

 

Loss of business, revenue, contracts, customers, profits, opportunities, anticipated savings, or goodwill;

 

Losses resulting from downtime, interruption, data corruption, or transmission delays;

 

Any obligation, fine, or loss arising from the Customer’s failure to comply with scheme rules, AML/CTF obligations, data protection laws, or instructions from Moneliq or its partners.

 

Financial Caps on Liability

For all other claims not excluded above, Moneliq’s maximum aggregate liability to the Customer in any twelve (12) month period shall not exceed the greater of:

 

The total Fees paid by the Customer to Moneliq for the relevant Service during the twelve (12) months immediately preceding the event giving rise to the claim; or

 

The minimum statutory cap required under applicable regulation or FCA guidance relevant to the Service type (acquiring, e-money, or payment services).

 

Each Service Schedule may specify separate caps, thresholds, or risk-weighted amounts in accordance with the operational and regulatory context. Where multiple Services are provided, the cap applies on a per-Service basis unless expressly stated otherwise in writing.

 

Where Moneliq processes transactions via third-party networks, partners, scheme providers, or APIs, Moneliq shall not be liable for any losses, delays, or failures caused by those third parties, provided Moneliq has acted with reasonable care and diligence.

 

Customer Indemnities

The Customer shall indemnify and hold harmless Moneliq, its officers, affiliates, employees, and partners from and against any and all claims, losses, damages, penalties, costs, or expenses (including reasonable legal and investigation costs) arising out of or connected with:

 

Breach by the Customer or any of its sub-clients of this Agreement, Service Schedules, or scheme/network rules;

 

Failure to perform required AML, CTF, or sanctions compliance obligations;

 

Any fraudulent, unlawful, or improper use of the Services or payment infrastructure;

 

Any data breach, chargeback, or misuse of confidential information;

 

Any regulatory or card scheme fines, penalties, or enforcement actions attributable to the Customer’s acts or omissions;

 

Any third-party claim arising from the Customer’s use or provision of Services to its own clients, end-users, or sub-merchants.

 

Mitigation and Aggregation

Each party shall take all reasonable steps to mitigate any loss or damage which it may suffer under this Agreement. Claims arising from the same or connected events shall be aggregated and treated as one claim for the purposes of calculating limits or caps under this clause.

 

Force Majeure and System Dependencies

Moneliq shall not be liable for any delay, suspension, or failure in performance resulting from strikes, labour disputes, industrial actions, acts of God, war, terrorism, embargo, regulatory actions, disruption or failure of telecommunications or banking networks, third-party provider failures, or any event beyond its reasonable control.

  1. Data Protection and Confidentiality

Both parties agree to comply with all applicable Data Protection Legislation, as defined in the Data Protection Act 2018 (“DPA”), the UK General Data Protection Regulation (“UK GDPR”), and any additional provisions in the relevant service schedules. Each party shall implement appropriate technical and organisational measures to safeguard personal data against unauthorised or unlawful processing, loss, destruction, or damage, in accordance with the standards required by law and guidance issued by the Information Commissioner’s Office (ICO).

 

Both parties acknowledge that any proprietary, commercially sensitive, or confidential information disclosed during the course of this Agreement must be kept strictly confidential and not used or disclosed except as necessary for the performance of this Agreement. Disclosure is permitted only where required by applicable law, regulation, or law enforcement authorities, including but not limited to obligations under the Financial Conduct Authority (“FCA”), money laundering regulations, or other regulatory directives.

 

Each party agrees not to disclose, publish, or otherwise make available any information belonging to the other party to any third party without prior written consent, except as may be required by law or regulatory mandate. All staff, contractors, and agents involved in the delivery of services under this Agreement shall be bound by equivalent confidentiality and data protection obligations.

 

Both parties shall take all reasonable steps to ensure the secure processing and transmission of data, utilizing industry-standard encryption, restricted access, monitoring, and incident management procedures. In the event of any actual or suspected data breach affecting personal data, proprietary or sensitive information shared under this Agreement, the affected party shall:

 

Notify the other party promptly and, in any event, within 24 hours of becoming aware of the incident.

 

Cooperate fully to investigate, mitigate, and remediate the breach, including fulfilling any statutory reporting obligations to the ICO and other relevant authorities.

 

Support the other party with any required regulatory or customer communications arising from the breach.

 

Upon expiration or termination of this Agreement, each party shall, as directed by the disclosing party, securely return or destroy all confidential information and personal data provided under this Agreement, save where retention is required for legal or regulatory compliance or legitimate business purposes.

  1. Notices

All notices, requests, consents, approvals, and other formal communications under or in connection with this Agreement must be in writing and delivered by hand, pre-paid recorded delivery, or sent by email to the addresses or contacts specified in the applicable Order Form, or such other contact details as either party may notify to the other in writing from time to time.

 

Notices shall be deemed to have been received:

 

if delivered by hand, on signature of a delivery receipt or at the time the notice is left at the correct address;

 

if sent by pre-paid recorded delivery or courier, at 9:00 a.m. on the second business day after posting;

 

if sent by email (to the designated business contact address), at the time of transmission as recorded by the sending party’s system, provided that no error message or notification of non-delivery has been received.

 

Communications between the parties relating to the operational performance of services, incident management, security notifications, or any matter concerning data protection, financial crime, or compliance obligations must be sent to the relevant designated compliance, risk, or operations contacts notified by each party in writing.

 

All regulatory or legal correspondence, including those from the FCA, HMRC, law enforcement, or data protection authorities, must be promptly forwarded to the receiving party’s compliance contact and acknowledged in writing within two business days.

 

Each party shall maintain appropriate records evidencing its communications under this Agreement and ensure that such records are retained for a minimum period of six (6) years or as required by applicable law and regulation.

 

Either party may update its notice details (including contact emails and postal addresses) by providing written notification to the other party, which will take effect five (5) business days after receipt, unless agreed otherwise in writing.

 

Where electronic signatures or communications are used, such communications shall be deemed duly executed and admissible as evidence in any legal or regulatory proceedings, provided they comply with applicable electronic communications and evidentiary rules in the United Kingdom.

  1. Delegation and Subcontracting

Moneliq may delegate or outsource certain operational, technical, or support functions to carefully selected third‑party providers, including technology partners, payment processors, banking partners, and open banking gateway providers. Any such arrangement will be managed in accordance with applicable regulatory requirements set out by the Financial Conduct Authority (FCA) and industry standards on outsourcing and operational resilience.

 

Where regulated activities or critical or important functions are outsourced, Moneliq retains full responsibility for the performance, compliance, and oversight of those service providers. Moneliq ensures that all delegated parties operate under written agreements that clearly define their obligations, maintain equivalent levels of security, confidentiality, and data protection, and allow for effective monitoring and audit.

 

All subcontracting and delegation arrangements are subject to due diligence, risk assessment, and ongoing performance review. Moneliq does not transfer its regulatory responsibilities under the Electronic Money Regulations 2011 or the Payment Services Regulations 2017 through outsourcing, and remains directly accountable for compliance with all applicable laws, customer protections, and regulatory reporting duties.

 

Moneliq may also rely on third‑party partners for open banking interfaces and API connectivity; however, all such integrations are subject to strict access controls, contractual safeguards, and continuous monitoring to ensure integrity, operational continuity, and security of customer data.

  1. Complaints Handling and Customer Redress

Moneliq is committed to providing high-quality services and resolving any concerns promptly and fairly. If you are dissatisfied with any aspect of our e-money, acquiring, money remittance, or open banking services, you may submit a complaint through any of the following channels:

 

  • Email: complaints@moneliq.com
  • Post: Complaints Department, Moneliq Ltd, 25 Cabot Square, London, England, E14 4QZ.
  • Online: Through your customer portal or the contact form on our website

 

We will acknowledge your complaint promptly and aim to issue a final response within 15 business days. In exceptional circumstances, where a full response cannot be provided within that timeframe, we will inform you of the reason and issue a final response within 35 business days, in accordance with the FCA’s DISP rules.

 

If you are an eligible complainant and are not satisfied with our response, you have the right to refer your complaint to the Financial Ombudsman Service (FOS) free of charge within six months of our final response. The FOS can be contacted at:

 

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

 

Telephone: 0800 023 4567

 

Website: www.financial-ombudsman.org.uk

 

We continuously review complaints to identify potential improvements to our products and services in line with our regulatory obligations and commitment to fair customer outcomes.

 

  1. Safeguarding of your Funds

Moneliq safeguards customer funds in accordance with the Electronic Money Regulations 2011. All funds received from customers in exchange for electronic money, or for the provision of payment services associated with e-money, are placed without delay into designated safeguarding accounts held with one or more authorised credit institutions or partner banks that meet FCA standards for safeguarding arrangements.

 

Moneliq maintains separate safeguarding accounts to ensure that safeguarded funds are kept distinct from its own operating funds and any other third-party monies. These accounts are subject to daily reconciliation to ensure the amount held matches the total value of customers’ e-money and payment funds. Any shortfall identified through reconciliation is corrected immediately, and any surplus is removed to maintain compliance with the safeguarding obligations under Regulation 21 of the EMRs.

 

The safeguarding process ensures that, in the event of Moneliq’s insolvency, customers’ funds remain protected and are distributed to them ahead of other creditors, following administration or liquidation procedures set out by the relevant insolvency legislation.

 

Our partner banks are subject to ongoing due diligence, contractual assurance, and periodic reviews to confirm that their safeguarding arrangements and account structures are operated in line with applicable FCA guidance and regulatory expectations.

 

Moneliq’s safeguarding records include detailed reconciliation logs, bank confirmations, and transaction journals maintained in compliance with regulatory recordkeeping requirements.

  1. Record Retention Periods

Moneliq maintains comprehensive records in accordance with the Money Laundering Regulations 2017 (as amended) and the FCA’s Senior Management Arrangements, Systems and Controls sourcebook (SYSC). These records include, but are not limited to, customer identification (KYC) documentation, transaction data, communications, risk assessments, and any other information relevant to our regulated activities.

 

All customer and transaction records are retained for a minimum period of five years from the date of the end of the business relationship or the completion of the transaction, whichever occurs later. Where required by law or regulatory instruction, Moneliq may retain certain records for up to six years or longer to meet legal, accounting, or investigative obligations.

 

Records are stored securely in electronic form to ensure integrity, confidentiality, and accessibility for regulatory review. Moneliq ensures that data retention and deletion practices comply with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  1. Security Details and Incident Handling

Moneliq employs robust information security and fraud prevention measures designed to protect customer data, safeguard transactions, and ensure the integrity of our payment, e-money, acquiring, remittance, and open banking services. Our security framework is aligned with industry standards and regulatory expectations, including the FCA’s requirements, the Payment Services Regulations 2017, and applicable ISO 27001 information security principles.

 

All sensitive data transmitted between customers, merchants, and Moneliq systems is encrypted and stored securely. Access to systems handling personal or financial information is strictly controlled, monitored, and subject to strong authentication mechanisms. Regular vulnerability assessments and penetration testing are conducted to identify and mitigate potential risks within Moneliq’s IT infrastructure and open banking APIs.

 

Customers must take reasonable precautions to keep their security credentials, API keys, or account access details confidential and must notify Moneliq immediately of any actual or suspected unauthorised access, fraud, or system compromise. Reports can be made to security@moneliq.com or via the in-app support feature.

 

In the event of a security or payment-related incident, Moneliq will investigate promptly, take necessary remedial measures, and, where required, inform affected customers and relevant authorities in accordance with regulatory reporting obligations under the FCA and the UK GDPR. This includes any suspected or actual Authorised Push Payment scam affecting your account, which you must report to us as soon as possible in accordance with Clause 5A.

 

Moneliq also operates an incident management policy ensuring all detected or reported threats are logged, reviewed, and resolved in line with our business continuity and operational resilience framework.

  1. Consumer Duty

Moneliq is committed to delivering good customer outcomes in accordance with the Financial Conduct Authority’s (FCA) Consumer Duty. This Duty underpins how Moneliq designs, delivers, and monitors its products, services, and customer communications across all areas of its business, including e-money issuance, merchant acquiring, money remittance, and open banking activities.

 

Moneliq ensures that products and services are designed to meet the needs, characteristics, and objectives of the identified target market, and that customers receive fair value throughout the entire relationship. The company proactively considers the diverse needs of its customers, including those in vulnerable circumstances, and takes steps to avoid foreseeable harm.

 

All customer interactions, whether marketing materials, website content, contractual documentation, or operational communications, are fair, clear, and not misleading. Moneliq aims to provide customers with the information, tools, and support they need to make effective, informed decisions about their use of Moneliq products and services.

 

To fulfil its Consumer Duty obligations, Moneliq:

 

Designs and reviews its products to ensure they offer fair value and meet identifiable customer needs.

 

Conducts ongoing assessments of customer outcomes, supported by management information, complaints analysis, and customer feedback.

 

Ensures pricing, fees, and charges are transparent and proportionate to the benefits customers receive.

 

Provides customers with accessible and timely support across all channels, ensuring issues are resolved promptly and fairly.

 

Maintains a culture of accountability and responsibility at all levels of the organisation, with governance structures that oversee the delivery of good customer outcomes.

 

Incorporates Consumer Duty considerations into product governance, risk management, and compliance monitoring frameworks.

 

Regularly reports to senior management and the Board on customer outcome metrics and takes remedial action when gaps or risks are identified.

 

Designing and operating fraud‑prevention, warning and APP Scam reimbursement processes that are consistent with regulatory requirements and support good customer outcomes.

 

Moneliq’s approach to Consumer Duty is embedded in its day-to-day operations and decision-making. The firm continually strives to enhance transparency, trust, and value in every aspect of its customer relationships.

  1. Governing Law and Jurisdiction

This Framework Agreement, together with all Schedules, Annexes, and any related documents or arrangements entered into pursuant to it, shall be governed by and construed in accordance with the laws of England and Wales.

 

The parties irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute, controversy, or claim (including non-contractual disputes or claims) arising out of or in connection with this Agreement, its subject matter, or formation.

 

Before initiating any legal proceedings, the parties shall first use best endeavours to resolve any dispute or disagreement through good faith negotiations between their respective senior management representatives. If such negotiations fail to resolve the matter within thirty (30) days of written notice of dispute, either party may refer the matter to mediation under the Centre for Effective Dispute Resolution (CEDR) Model Mediation Procedure before resorting to litigation, unless urgent injunctive, equitable, or regulatory relief is required.

 

Nothing in this clause shall prevent either party from seeking interim or injunctive relief, or from fulfilling any mandatory reporting or co‑operation obligation with a regulator, supervisory authority, or law enforcement agency, including but not limited to the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), Information Commissioner’s Office (ICO), or HM Revenue & Customs (HMRC).

 

The parties acknowledge that the services provided under this Agreement, including acquiring, e-money issuance, open banking, and remittance, are subject to applicable UK and international regulatory frameworks. Accordingly, where regulatory interpretation or intervention is required, the parties shall comply with all directions or determinations made by the relevant competent authority.

 

Each party waives any objection to proceedings in the courts of England and Wales on the grounds of inconvenient forum or any similar basis and agrees that any judgment or order of such courts shall be final and binding, subject only to rights of appeal under English law.

 

This clause shall survive termination or expiry of the Agreement.

  1. Schedules

SCHEDULE 1 – Service Description (by type: e-money, acquiring, remittance, open banking)

SCHEDULE 2 – Fees and Volume Charges

SCHEDULE 3 – Conflicts & Precedence (Order form, then Service Schedules, then Framework)

SCHEDULE 4 – Sub-client/Agency/End User Terms

SCHEDULE 5 – Data Processing & Information Security Addendum

 

INTEGRATION OF ATTACHED AGREEMENTS

For all service-specific standards (e.g., card acquiring, web payments, rolling reserve, fraud, indemnity, KYC, disputes, settlement timing, Open Banking integrations etc.), this Framework incorporates, mutatis mutandis, all operative legal, regulatory and commercial provisions of your provided agreement

MONELIQ LIMITED | 25 Cabot Square, London, United Kingdom, E14 4QZ

Authorised Electronic Money Institution, regulated by FCA, License reference number 901056

Personal

Business

Terms and Conditions

Framework Agreement

Moneliq Limited (Company Number: 12213334) is a company registered in England and Wales, with its registered office at 25 Cabot Square, London, England, E14 4QZ.

Moneliq Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Electronic Money Institution under the Electronic Money Regulations 2011. Our FCA Firm Reference Number (“FRN”) is 901056.

You can verify our regulatory status by visiting the  FCA Register and searching for “Moneliq Limited” or by using our Firm Reference Number (FRN) 901056.

This Agreement is entered into for the Provision of Electronic Money, Payment Acquisition, Money Remittance, and Open Banking Services (AIS/PIS).

  1. Definitions and Interpretation

"Agreement": This framework and its schedules/annexes.

 

"Customer": The client contracting with Moneliq for one or more services under this Agreement.

 

"Services": E-Money issuance/redeeming, payment acquiring, money remittance, AIS, PIS (as described in Schedule 1).

 

"Open Banking": Access to AIS and PIS under the Payment Services Regulations 2017 (SI 2017/752).

 

"Acquirer" "Merchant" "Sub-Client" and other stakeholder terms use definitions as per all forms​ accompanied.

 

Interpretations, subdivision precedence, and other legal construction terms as set out in the attached agreements.​

  1. Scope of Services/Provision of Services

Moneliq will provide the Customer with one or more of the following, in the UK and EU:

 

E-Money Issue & Redemption: Issue, store, redeem electronic money in compliance with UK EMRs​. Important: Electronic money issued by Moneliq is not a deposit and is not protected by the Financial Services Compensation Scheme. Customer funds are safeguarded in compliance with the Electronic Money Regulations 2011 but will not benefit from FSCS protection.

 

Acquiring Services: Enable merchant acceptance and processing of payment transactions (cards or alternative methods)​.

 

Money Remittance: Facilitate payment orders and funds remittance for and on behalf of Customer.

 

Open Banking (AIS/PIS): Provide access to Account Information Services and Payment Initiation Services through Moneliq or as agent of a regulated provider.

 

Sub-clients: Where agreed, Moneliq may enable Customer’s connected sub-clients to utilise the Services, subject to due diligence and ongoing compliance oversight​.

 

  • 2.1 In consideration of payment by the Merchant of the Charges and Fees, Moneliq agrees, subject to the terms and conditions of the Agreement, to provide the Merchant with the Services as initially selected in the Application Documentation and amended, updated, supplemented and/or replaced from time to time in accordance with the Agreement. The Merchant can ask Moneliq for a copy of the Agreement at any time.

 

  • 2.2 Moneliq may from time to time provide the Merchant with Additional Services. Each Additional Service will be governed by the Additional Service Conditions applicable to it as well as the other terms and conditions of the Agreement. The Additional Service Conditions will be provided to the Merchant as and when they are applicable to the Merchant and the Agreement. The Merchant must pay the Charges and Fees (plus VAT, where applicable) relating to any Additional Service in accordance with the applicable Additional Service Conditions and the other parts of the Agreement.

 

  • 2.3 If the Merchant requires any additional product and/or service from Moneliq, which is not offered by Moneliq in the form of an Additional Service or other element of the Services, the Merchant shall issue a written request to Moneliq and, where Moneliq is willing to provide the relevant product and/or service, Moneliq shall propose a separate written agreement setting out the terms and conditions on which it is willing to provide such product and/or service ("Separate Agreement"). Unless and until such time as a Separate Agreement has been agreed and signed by or on behalf of the parties to govern Moneliq's provision of any additional product and/or service requested by the Merchant, Moneliq shall not be under any obligation to provide the relevant product and/or service. Once agreed and signed by or on behalf of the parties, each Separate Agreement will be entirely independent and separate from the Agreement.

 

  • 2.4 Consumer Protection and FSCS Disclosure

 

  • Moneliq is authorised by the Financial Conduct Authority (FCA) as an Electronic Money Institution. Funds held with Moneliq in connection with your e-money account, acquiring services, money remittance, or open banking activities are not deposits and do not earn interest. Your funds are not covered by the Financial Services Compensation Scheme (FSCS).

 

  • However, in accordance with the FCA’s safeguarding requirements, we protect your money by placing it into segregated safeguarding accounts with regulated credit institutions. This ensures that your funds remain separate from Moneliq’s own funds and are protected in the event of our insolvency.
  1. Term and Termination

This Agreement is effective from the date of execution, for an indefinite term, subject to initial/renewal periods as set out in the relevant Service Schedules.

 

Either party may terminate on not less than 2 months’ written notice (for ongoing services) or as per specific event/cause as detailed in attached forms (e.g. breach, insolvency, regulatory risk, or account inactivity).​

 

Moneliq may terminate or suspend some or all services immediately upon regulatory breach, security incident, non-payment, change to prohibited business, or where required by applicable law.

 

Change Control and Variation Process:

 

Moneliq may amend the terms of this Agreement, including changes to the services we provide, operational processes, or pricing, to reflect legal, regulatory, or business requirements.

 

We will provide you with at least 60 days’ written notice before any change takes effect, unless a shorter period is required by law or is necessary to address fraud prevention, security, or compliance matters. The updated terms will be made available on our website and, where applicable, communicated through your registered email or customer dashboard.

 

If you do not agree to the changes, you may terminate this Agreement free of charge before the effective date of the changes. Your continued use of our services after the effective date will constitute acceptance of the revised terms.

 

Any changes that do not affect your rights or obligations materially, such as minor editorial or administrative updates, may be made without prior notice but will be published promptly on our website.

  1. Fees and Payment

Fees, minimum monthly commitments, and tariffs for each Service are set out in the applicable Schedule(s) or Service Order Forms. Fees may include set-up, monthly, per-transaction, and volume-based charges.

 

Additional fees (e.g., chargebacks, card scheme penalties, investigation costs, reserves/rolling reserve, chargeback fees, fraud screening) may be applied as outlined.

 

Moneliq will invoice for Services in accordance with the agreed billing terms. All invoices must be paid within thirty (30) days of the invoice date. Interest on overdue amounts shall accrue at the rate specified in this Agreement or, if not stated, at the statutory rate under the Late Payment of Commercial Debts (Interest) Act 1998.

 

You may request redemption of your e-money balance at any time, subject to Moneliq’s published redemption procedures and any applicable fees set out in the relevant Service Schedule. Redemption requests will be processed promptly and no later than the end of the business day following receipt, unless further information is required to comply with legal or regulatory obligations.

  1. Service Obligations & Limitations

Customer must comply with all applicable laws, provide accurate information, maintain valid authorisations and licenses, and not use services for unlawful or restricted activities.

 

Moneliq reserves the right to:

 

Review and adjust its Fees or pricing structure at any time, by providing not less than sixty (60) days' written notice to the Customer.

 

Deduct or offset any unpaid or disputed sums, chargebacks, penalties, or other liabilities arising under this Agreement from settlement or payout amounts due to the Customer.

 

Require pre-funding, security deposits, or reserves (including rolling or capped reserves) where Moneliq reasonably determines that increased risk, exposure, or non-compliance may exist.

 

Suspend or withhold the settlement of funds in the event of suspected fraud, chargeback activity, a regulatory investigation, or a breach of any applicable regulatory, card network, or scheme rules.

 

All fees and charges are exclusive of VAT and any other applicable taxes, which shall be payable by the Customer in addition to the quoted amounts.

 

The Customer must comply with all applicable laws, regulations, and regulatory guidance, including but not limited to the Financial Services and Markets Act 2000, the Electronic Money Regulations 2011 (EMR), the Payment Services Regulations 2017 (PSR), the Data Protection Act 2018, the UK GDPR, and guidance issued by the FCA and relevant card schemes. The Customer shall provide accurate, complete, and up-to-date information to Moneliq at all times, maintain valid authorisations, licences, and approvals, and ensure that its business activities are lawful and properly disclosed. Services must not be used for any prohibited, unlawful, or restricted purposes as defined by Moneliq’s Acceptable Use Policy or relevant regulatory standards.

 

Acquiring and Card Acceptance Obligations

For the provision of card acquiring and acceptance services, the Customer must:

 

Adhere at all times to all applicable card scheme rules, network operating regulations, and any technical standards mandated by other scheme partners.

 

Not exceed published or permitted thresholds for chargebacks, fraud, or excessive refund activity.

 

Maintain appropriate fraud prevention, transaction validation, and dispute management controls.

 

Display scheme marks, acceptance logos, and required disclosures in accordance with card scheme and Moneliq branding requirements.

 

Maintain PCI DSS compliance and security of cardholder data, including not storing or transmitting sensitive authentication data except as permitted by scheme standards.

 

Notify Moneliq immediately of any suspected data breach, compromise, or unauthorised transaction activity.

 

Refrain from surcharge practices or transaction routing that breach scheme or legal requirements.

 

E-Money Services

For E-Money accounts and issuance:

 

The Customer acknowledges that all client funds are safeguarded in accordance with Regulation 20 of the EMR and are segregated from Moneliq’s own funds.

 

Funds held as e-money are not deposits and are not covered by the Financial Services Compensation Scheme (FSCS).

 

Interest or equivalent benefits are not payable on e-money balances.

 

The Customer retains a redemption right in accordance with the EMR, subject to Moneliq’s applicable redemption procedures, fees, and timeframes.

 

Any misuse of the e-money platform or breach of AML/CTF rules may result in immediate suspension or termination of the service.

 

Open Banking Services

For access to Open Banking services:

 

The Customer must obtain and maintain all consents and permissions from its users required under the PSR, FCA rules, and Moneliq’s technical and data sharing agreements.

 

Data access and processing must be clear, informed, and transparent, with user consent recorded and maintained.

 

All personal data processing must be conducted in full compliance with the Data Protection Act 2018, UK GDPR, and Moneliq’s Data Processing Agreement (DPA) and associated addendums.

 

The Customer must not misuse, retain, or share account information beyond the purpose authorised by the account holder or allowed by Moneliq.

 

Any data subject or withdrawal of consent notices must be communicated promptly to Moneliq.

 

Remittance and Cross-Border Payments

For remittance and money transfer services:

 

The Customer must comply with all AML/CTF obligations under the Money Laundering Regulations 2017 (as amended), including appropriate KYC and ongoing transaction monitoring.

 

The Customer must not process payments for sanctioned individuals or jurisdictions listed under UK, EU, OFAC, or UN sanctions lists.

 

All originator and beneficiary information must be accurate, traceable, and retained in accordance with FATF Recommendation 16 and UK requirements on wire transfers.

 

The Customer accepts that Moneliq may delay, suspend, or refuse transactions where required to comply with legal, regulatory, or risk management obligations.

 

General Limitations and Rights

Moneliq may:

 

Amend or withdraw any service in response to regulatory, scheme, or partner requirements, providing reasonable notice where practicable.

 

Suspend services, settlements, or account access if risk levels, breaches, or investigations arise.

 

Require enhanced due diligence (EDD), security deposits, or adjusted transaction limits based on risk profiling.

 

Share information with regulators, law enforcement, and scheme partners as required under applicable laws and regulatory obligations.

 

The Customer remains fully responsible for all acts, omissions, and compliance of its employees, agents, and sub-merchants (where applicable) in connection with the use of the Services.

 

  • 5A.2 Eligibility
  • The APP reimbursement provisions apply to Customers and End Users who meet the eligibility criteria under the applicable APP reimbursement rules (including consumers, micro‑enterprises and charities within the relevant thresholds).

 

  • A claim must relate to one or more In‑Scope Payment Systems payments made on or after 7 October 2024 and must be raised no later than 13 months after the date of the last payment made as part of the same scam.

 

  • 5A.3 Reimbursement and limits
  • Subject to clauses 5A.4 and 5A.5, where an eligible Customer or End User has fallen victim to an APP Scam in relation to an In‑Scope Payment Systems payment, Moneliq (acting as sending payment service provider) will reimburse the Customer for the Reimbursable Amount in accordance with the mandatory requirements set by the Payment Systems Regulator.

 

  • The Reimbursable Amount for any single APP Scam is subject to the maximum reimbursement cap in force under the APP reimbursement rules (currently £85,000 per claim, including all related payments that form part of the same scam) and any permitted excess which Moneliq may apply (currently £100 per claim).

 

  • Moneliq will normally make reimbursement within five Business Days of determining that the claim is in scope, subject to any permitted “stop‑the‑clock” pauses where additional information or co‑operation is required.

 

  • 5A.4 Customer standard of caution and co‑operation
  • To be eligible for reimbursement, the Customer and any End User must:
    • (a) take reasonable steps to protect themselves from scams, including reading and acting on any warnings presented in Moneliq’s channels at or before the time of payment;
    • (b) carry out basic checks where prompted (for example, contacting the payee using trusted contact details, and considering whether the payment request is consistent with their usual dealings); and
    • (c) report suspected APP Scams to Moneliq as soon as reasonably practicable and, in any event, within 13 months of the last payment related to the scam, and respond truthfully and promptly to Moneliq’s reasonable information requests.

 

  • Moneliq will have regard to FCA expectations and the Consumer Duty when assessing whether the Customer has met the required standard of caution, particularly where vulnerability may have had a material impact on their ability to protect themselves.

 

  • 5A.5 Exceptions to reimbursement
  • Moneliq may decline reimbursement where:
    • (a) the Customer or End User has acted fraudulently (first‑party fraud); or
    • (b) the Customer or End User has acted with gross negligence in failing to meet the standard of caution set out in clause 5A.4, taking into account applicable regulatory rules and guidance; or
    • (c) the payment is outside the scope of the APP reimbursement rules (including, without limitation, payments executed before 7 October 2024, payments outside the In‑Scope Payment Systems, or payments to an account owned or controlled by the Customer).

 

  • Moneliq will not treat a Customer as grossly negligent solely because they have fallen victim to a sophisticated scam. Moneliq will assess each case individually, considering all relevant evidence and any indicators of vulnerability.

 

  • 5A.6 Receiving‑PSP and “on‑us” payments
  • Where Moneliq acts as receiving payment service provider in relation to an APP Scam, Moneliq will meet any contribution obligations owed to the sending payment service provider under the applicable APP reimbursement rules.

 

  • Where both the sending and receiving accounts are held with Moneliq (“on‑us” payments), Moneliq will apply protections that are at least equivalent to those that would apply if the payment were executed over an In‑Scope Payment System, subject to any differences permitted under applicable regulation and guidance.

 

  • 5A.7 Process and complaints
  • Customers can raise an APP Scam claim using the usual incident reporting channels set out in Clause 14 and may submit a complaint under Clause 11 if dissatisfied with the handling or outcome of a claim.

 

  • If the Customer remains dissatisfied and is an eligible complainant, the Customer may refer the matter to the Financial Ombudsman Service in accordance with Clause 11.
  1. Due Diligence, AML, Sub-Clients

Moneliq (and, where applicable, its regulated partners will perform all necessary Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and sanctions screening checks on all Customers and, where applicable, on any of their sub-clients or associated entities. The Customer acknowledges that services are conditional upon successful completion of these checks, and Moneliq reserves the right to decline, restrict, or terminate services where onboarding requirements are not met or where ongoing monitoring identifies material risk.

 

The Customer shall fully cooperate with Moneliq and its partners in providing information, documentation, and evidence as requested at any stage for initial verification or ongoing monitoring, including but not limited to:

 

Corporate and ownership documentation identifying ultimate beneficial owners (UBOs).

 

Details of directors, controllers, and authorised representatives.

 

Proof of business activities, source of funds, and expected transaction volumes and counterparties.

 

Periodic reviews, sanctions and PEP (Politically Exposed Person) screening confirmations.

 

Transaction-level information requested for investigations or suspicious activity reviews.

Failure to provide accurate or timely information constitutes a material breach of this Agreement and may result in service suspension, delayed settlement, or termination as deemed necessary by Moneliq.

 

Customer Due Diligence and Sub-Client Responsibilities

Where the Customer introduces, onboards, or processes transactions for third parties (“sub-clients”, “merchants”, or “end users”), the Customer is solely responsible for performing adequate due diligence and risk assessment on each such sub-client and maintaining full visibility and control over their activities. The Customer must:

 

Implement and maintain AML, CTF, and sanctions policies, systems, and controls proportionate to its business and risk profile.

 

Identify and verify each sub-client’s legal identity, ownership, and business nature before permitting access to any payment, e-money, or acquiring service.

 

Conduct ongoing monitoring of sub-clients’ transactions, ensuring continuous compliance with AML and fraud prevention standards.

 

Ensure sub-clients do not use the services for illegal, high-risk, or prohibited activities as defined under Moneliq’s Acceptable Use Policy and applicable FCA/AML rules.

 

Retain records of all KYC and transactional information for a minimum of five (5) years or longer where required by law.

 

Immediately report to Moneliq any suspicious, unusual, or high-risk activity and cooperate with requests for supporting documentation or data.

 

Monitoring, Reporting, and Cooperation

Moneliq and its regulated partners will perform ongoing transaction monitoring, sanctions checks, and screening of all transactional activity to detect, prevent, and report suspicious transactions in line with the Money Laundering Regulations 2017 (as amended) and FCA supervisory expectations. The Customer acknowledges and agrees that:

 

Moneliq may delay, freeze, or decline transactions where enhanced due diligence or investigation is required.

 

Certain information may be disclosed to regulatory or law enforcement authorities where required under applicable laws.

 

Moneliq may impose enhanced due diligence (EDD), limit transactions, or adjust settlement timing for higher-risk customers or sub-clients.

 

Any failure to respond to AML, sanctions, or fraud-related information requests within the specified timeframe may result in the immediate suspension or termination of services.

 

Audit and Verification Rights

Moneliq reserves the right to audit or review the Customer’s AML and compliance procedures, either directly or through appointed representatives, at reasonable intervals. Such reviews may include inspection of KYC records, monitoring reports, and control procedures relating to sub-clients. The Customer shall grant timely access to all requested materials and cooperate fully with any audit process.

 

Where deficiencies or policy breaches are identified, Moneliq may issue remediation requirements that must be completed within a specified period. Failure to remedy such issues constitutes a material breach of this Agreement and may lead to service suspension or termination.

 

The parties acknowledge that Moneliq remains ultimately responsible for maintaining compliance with regulatory obligations under the EMR, PSR, and MLR, and that cooperation with its due diligence and oversight functions is a strict condition of continued service provision.​

  1. Liability and Indemnity

Each party’s liability under this Agreement is subject to the exclusions and limitations of liability set out within this clause and, where applicable, within the individual Service Schedules or Order Forms. Liability provisions apply collectively across all Services provided by Moneliq and its regulated partners, including (without limitation) acquiring, e-money, Open Banking, and remittance services.

 

Exclusions and Non-Limited Liabilities

Nothing in this Agreement excludes or limits either party’s liability for:

 

Death or personal injury caused by its negligence or that of its employees or agents.

 

Fraud, fraudulent misrepresentation, or wilful misconduct.

 

Breach of any regulatory obligation or indemnity provided under this Agreement.

 

Any other liability that cannot lawfully be excluded or limited under applicable law.

 

Except as set out above, Moneliq shall not be liable for:

 

Any indirect, special, incidental, punitive, or consequential loss;

 

Loss of business, revenue, contracts, customers, profits, opportunities, anticipated savings, or goodwill;

 

Losses resulting from downtime, interruption, data corruption, or transmission delays;

 

Any obligation, fine, or loss arising from the Customer’s failure to comply with scheme rules, AML/CTF obligations, data protection laws, or instructions from Moneliq or its partners.

 

Financial Caps on Liability

For all other claims not excluded above, Moneliq’s maximum aggregate liability to the Customer in any twelve (12) month period shall not exceed the greater of:

 

The total Fees paid by the Customer to Moneliq for the relevant Service during the twelve (12) months immediately preceding the event giving rise to the claim; or

 

The minimum statutory cap required under applicable regulation or FCA guidance relevant to the Service type (acquiring, e-money, or payment services).

 

Each Service Schedule may specify separate caps, thresholds, or risk-weighted amounts in accordance with the operational and regulatory context. Where multiple Services are provided, the cap applies on a per-Service basis unless expressly stated otherwise in writing.

 

Where Moneliq processes transactions via third-party networks, partners, scheme providers, or APIs, Moneliq shall not be liable for any losses, delays, or failures caused by those third parties, provided Moneliq has acted with reasonable care and diligence.

 

Customer Indemnities

The Customer shall indemnify and hold harmless Moneliq, its officers, affiliates, employees, and partners from and against any and all claims, losses, damages, penalties, costs, or expenses (including reasonable legal and investigation costs) arising out of or connected with:

 

Breach by the Customer or any of its sub-clients of this Agreement, Service Schedules, or scheme/network rules;

 

Failure to perform required AML, CTF, or sanctions compliance obligations;

 

Any fraudulent, unlawful, or improper use of the Services or payment infrastructure;

 

Any data breach, chargeback, or misuse of confidential information;

 

Any regulatory or card scheme fines, penalties, or enforcement actions attributable to the Customer’s acts or omissions;

 

Any third-party claim arising from the Customer’s use or provision of Services to its own clients, end-users, or sub-merchants.

 

Mitigation and Aggregation

Each party shall take all reasonable steps to mitigate any loss or damage which it may suffer under this Agreement. Claims arising from the same or connected events shall be aggregated and treated as one claim for the purposes of calculating limits or caps under this clause.

 

Force Majeure and System Dependencies

Moneliq shall not be liable for any delay, suspension, or failure in performance resulting from strikes, labour disputes, industrial actions, acts of God, war, terrorism, embargo, regulatory actions, disruption or failure of telecommunications or banking networks, third-party provider failures, or any event beyond its reasonable control.

  1. Data Protection and Confidentiality

Both parties agree to comply with all applicable Data Protection Legislation, as defined in the Data Protection Act 2018 (“DPA”), the UK General Data Protection Regulation (“UK GDPR”), and any additional provisions in the relevant service schedules. Each party shall implement appropriate technical and organisational measures to safeguard personal data against unauthorised or unlawful processing, loss, destruction, or damage, in accordance with the standards required by law and guidance issued by the Information Commissioner’s Office (ICO).

 

Both parties acknowledge that any proprietary, commercially sensitive, or confidential information disclosed during the course of this Agreement must be kept strictly confidential and not used or disclosed except as necessary for the performance of this Agreement. Disclosure is permitted only where required by applicable law, regulation, or law enforcement authorities, including but not limited to obligations under the Financial Conduct Authority (“FCA”), money laundering regulations, or other regulatory directives.

 

Each party agrees not to disclose, publish, or otherwise make available any information belonging to the other party to any third party without prior written consent, except as may be required by law or regulatory mandate. All staff, contractors, and agents involved in the delivery of services under this Agreement shall be bound by equivalent confidentiality and data protection obligations.

 

Both parties shall take all reasonable steps to ensure the secure processing and transmission of data, utilizing industry-standard encryption, restricted access, monitoring, and incident management procedures. In the event of any actual or suspected data breach affecting personal data, proprietary or sensitive information shared under this Agreement, the affected party shall:

 

Notify the other party promptly and, in any event, within 24 hours of becoming aware of the incident.

 

Cooperate fully to investigate, mitigate, and remediate the breach, including fulfilling any statutory reporting obligations to the ICO and other relevant authorities.

 

Support the other party with any required regulatory or customer communications arising from the breach.

 

Upon expiration or termination of this Agreement, each party shall, as directed by the disclosing party, securely return or destroy all confidential information and personal data provided under this Agreement, save where retention is required for legal or regulatory compliance or legitimate business purposes.

  1. Notices

All notices, requests, consents, approvals, and other formal communications under or in connection with this Agreement must be in writing and delivered by hand, pre-paid recorded delivery, or sent by email to the addresses or contacts specified in the applicable Order Form, or such other contact details as either party may notify to the other in writing from time to time.

 

Notices shall be deemed to have been received:

 

if delivered by hand, on signature of a delivery receipt or at the time the notice is left at the correct address;

 

if sent by pre-paid recorded delivery or courier, at 9:00 a.m. on the second business day after posting;

 

if sent by email (to the designated business contact address), at the time of transmission as recorded by the sending party’s system, provided that no error message or notification of non-delivery has been received.

 

Communications between the parties relating to the operational performance of services, incident management, security notifications, or any matter concerning data protection, financial crime, or compliance obligations must be sent to the relevant designated compliance, risk, or operations contacts notified by each party in writing.

 

All regulatory or legal correspondence, including those from the FCA, HMRC, law enforcement, or data protection authorities, must be promptly forwarded to the receiving party’s compliance contact and acknowledged in writing within two business days.

 

Each party shall maintain appropriate records evidencing its communications under this Agreement and ensure that such records are retained for a minimum period of six (6) years or as required by applicable law and regulation.

 

Either party may update its notice details (including contact emails and postal addresses) by providing written notification to the other party, which will take effect five (5) business days after receipt, unless agreed otherwise in writing.

 

Where electronic signatures or communications are used, such communications shall be deemed duly executed and admissible as evidence in any legal or regulatory proceedings, provided they comply with applicable electronic communications and evidentiary rules in the United Kingdom.

  1. Delegation and Subcontracting

Moneliq may delegate or outsource certain operational, technical, or support functions to carefully selected third‑party providers, including technology partners, payment processors, banking partners, and open banking gateway providers. Any such arrangement will be managed in accordance with applicable regulatory requirements set out by the Financial Conduct Authority (FCA) and industry standards on outsourcing and operational resilience.

 

Where regulated activities or critical or important functions are outsourced, Moneliq retains full responsibility for the performance, compliance, and oversight of those service providers. Moneliq ensures that all delegated parties operate under written agreements that clearly define their obligations, maintain equivalent levels of security, confidentiality, and data protection, and allow for effective monitoring and audit.

 

All subcontracting and delegation arrangements are subject to due diligence, risk assessment, and ongoing performance review. Moneliq does not transfer its regulatory responsibilities under the Electronic Money Regulations 2011 or the Payment Services Regulations 2017 through outsourcing, and remains directly accountable for compliance with all applicable laws, customer protections, and regulatory reporting duties.

 

Moneliq may also rely on third‑party partners for open banking interfaces and API connectivity; however, all such integrations are subject to strict access controls, contractual safeguards, and continuous monitoring to ensure integrity, operational continuity, and security of customer data.

  1. Complaints Handling and Customer Redress

Moneliq is committed to providing high-quality services and resolving any concerns promptly and fairly. If you are dissatisfied with any aspect of our e-money, acquiring, money remittance, or open banking services, you may submit a complaint through any of the following channels:

 

  • Email: complaints@moneliq.com
  • Post: Complaints Department, Moneliq Ltd, 25 Cabot Square, London, England, E14 4QZ.
  • Online: Through your customer portal or the contact form on our website

 

We will acknowledge your complaint promptly and aim to issue a final response within 15 business days. In exceptional circumstances, where a full response cannot be provided within that timeframe, we will inform you of the reason and issue a final response within 35 business days, in accordance with the FCA’s DISP rules.

 

If you are an eligible complainant and are not satisfied with our response, you have the right to refer your complaint to the Financial Ombudsman Service (FOS) free of charge within six months of our final response. The FOS can be contacted at:

 

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

 

Telephone: 0800 023 4567

 

Website: www.financial-ombudsman.org.uk

 

We continuously review complaints to identify potential improvements to our products and services in line with our regulatory obligations and commitment to fair customer outcomes.

 

  1. Safeguarding of your Funds

Moneliq safeguards customer funds in accordance with the Electronic Money Regulations 2011. All funds received from customers in exchange for electronic money, or for the provision of payment services associated with e-money, are placed without delay into designated safeguarding accounts held with one or more authorised credit institutions or partner banks that meet FCA standards for safeguarding arrangements.

 

Moneliq maintains separate safeguarding accounts to ensure that safeguarded funds are kept distinct from its own operating funds and any other third-party monies. These accounts are subject to daily reconciliation to ensure the amount held matches the total value of customers’ e-money and payment funds. Any shortfall identified through reconciliation is corrected immediately, and any surplus is removed to maintain compliance with the safeguarding obligations under Regulation 21 of the EMRs.

 

The safeguarding process ensures that, in the event of Moneliq’s insolvency, customers’ funds remain protected and are distributed to them ahead of other creditors, following administration or liquidation procedures set out by the relevant insolvency legislation.

 

Our partner banks are subject to ongoing due diligence, contractual assurance, and periodic reviews to confirm that their safeguarding arrangements and account structures are operated in line with applicable FCA guidance and regulatory expectations.

 

Moneliq’s safeguarding records include detailed reconciliation logs, bank confirmations, and transaction journals maintained in compliance with regulatory recordkeeping requirements.

  1. Record Retention Periods

Moneliq maintains comprehensive records in accordance with the Money Laundering Regulations 2017 (as amended) and the FCA’s Senior Management Arrangements, Systems and Controls sourcebook (SYSC). These records include, but are not limited to, customer identification (KYC) documentation, transaction data, communications, risk assessments, and any other information relevant to our regulated activities.

 

All customer and transaction records are retained for a minimum period of five years from the date of the end of the business relationship or the completion of the transaction, whichever occurs later. Where required by law or regulatory instruction, Moneliq may retain certain records for up to six years or longer to meet legal, accounting, or investigative obligations.

 

Records are stored securely in electronic form to ensure integrity, confidentiality, and accessibility for regulatory review. Moneliq ensures that data retention and deletion practices comply with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  1. Security Details and Incident Handling

Moneliq employs robust information security and fraud prevention measures designed to protect customer data, safeguard transactions, and ensure the integrity of our payment, e-money, acquiring, remittance, and open banking services. Our security framework is aligned with industry standards and regulatory expectations, including the FCA’s requirements, the Payment Services Regulations 2017, and applicable ISO 27001 information security principles.

 

All sensitive data transmitted between customers, merchants, and Moneliq systems is encrypted and stored securely. Access to systems handling personal or financial information is strictly controlled, monitored, and subject to strong authentication mechanisms. Regular vulnerability assessments and penetration testing are conducted to identify and mitigate potential risks within Moneliq’s IT infrastructure and open banking APIs.

 

Customers must take reasonable precautions to keep their security credentials, API keys, or account access details confidential and must notify Moneliq immediately of any actual or suspected unauthorised access, fraud, or system compromise. Reports can be made to security@moneliq.com or via the in-app support feature.

 

In the event of a security or payment-related incident, Moneliq will investigate promptly, take necessary remedial measures, and, where required, inform affected customers and relevant authorities in accordance with regulatory reporting obligations under the FCA and the UK GDPR. This includes any suspected or actual Authorised Push Payment scam affecting your account, which you must report to us as soon as possible in accordance with Clause 5A.

 

Moneliq also operates an incident management policy ensuring all detected or reported threats are logged, reviewed, and resolved in line with our business continuity and operational resilience framework.

  1. Consumer Duty

Moneliq is committed to delivering good customer outcomes in accordance with the Financial Conduct Authority’s (FCA) Consumer Duty. This Duty underpins how Moneliq designs, delivers, and monitors its products, services, and customer communications across all areas of its business, including e-money issuance, merchant acquiring, money remittance, and open banking activities.

 

Moneliq ensures that products and services are designed to meet the needs, characteristics, and objectives of the identified target market, and that customers receive fair value throughout the entire relationship. The company proactively considers the diverse needs of its customers, including those in vulnerable circumstances, and takes steps to avoid foreseeable harm.

 

All customer interactions, whether marketing materials, website content, contractual documentation, or operational communications, are fair, clear, and not misleading. Moneliq aims to provide customers with the information, tools, and support they need to make effective, informed decisions about their use of Moneliq products and services.

 

To fulfil its Consumer Duty obligations, Moneliq:

 

Designs and reviews its products to ensure they offer fair value and meet identifiable customer needs.

 

Conducts ongoing assessments of customer outcomes, supported by management information, complaints analysis, and customer feedback.

 

Ensures pricing, fees, and charges are transparent and proportionate to the benefits customers receive.

 

Provides customers with accessible and timely support across all channels, ensuring issues are resolved promptly and fairly.

 

Maintains a culture of accountability and responsibility at all levels of the organisation, with governance structures that oversee the delivery of good customer outcomes.

 

Incorporates Consumer Duty considerations into product governance, risk management, and compliance monitoring frameworks.

 

Regularly reports to senior management and the Board on customer outcome metrics and takes remedial action when gaps or risks are identified.

 

Designing and operating fraud‑prevention, warning and APP Scam reimbursement processes that are consistent with regulatory requirements and support good customer outcomes.

 

Moneliq’s approach to Consumer Duty is embedded in its day-to-day operations and decision-making. The firm continually strives to enhance transparency, trust, and value in every aspect of its customer relationships.

  1. Governing Law and Jurisdiction

This Framework Agreement, together with all Schedules, Annexes, and any related documents or arrangements entered into pursuant to it, shall be governed by and construed in accordance with the laws of England and Wales.

 

The parties irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute, controversy, or claim (including non-contractual disputes or claims) arising out of or in connection with this Agreement, its subject matter, or formation.

 

Before initiating any legal proceedings, the parties shall first use best endeavours to resolve any dispute or disagreement through good faith negotiations between their respective senior management representatives. If such negotiations fail to resolve the matter within thirty (30) days of written notice of dispute, either party may refer the matter to mediation under the Centre for Effective Dispute Resolution (CEDR) Model Mediation Procedure before resorting to litigation, unless urgent injunctive, equitable, or regulatory relief is required.

 

Nothing in this clause shall prevent either party from seeking interim or injunctive relief, or from fulfilling any mandatory reporting or co‑operation obligation with a regulator, supervisory authority, or law enforcement agency, including but not limited to the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), Information Commissioner’s Office (ICO), or HM Revenue & Customs (HMRC).

 

The parties acknowledge that the services provided under this Agreement, including acquiring, e-money issuance, open banking, and remittance, are subject to applicable UK and international regulatory frameworks. Accordingly, where regulatory interpretation or intervention is required, the parties shall comply with all directions or determinations made by the relevant competent authority.

 

Each party waives any objection to proceedings in the courts of England and Wales on the grounds of inconvenient forum or any similar basis and agrees that any judgment or order of such courts shall be final and binding, subject only to rights of appeal under English law.

 

This clause shall survive termination or expiry of the Agreement.

  1. Schedules

SCHEDULE 1 – Service Description (by type: e-money, acquiring, remittance, open banking)

SCHEDULE 2 – Fees and Volume Charges

SCHEDULE 3 – Conflicts & Precedence (Order form, then Service Schedules, then Framework)

SCHEDULE 4 – Sub-client/Agency/End User Terms

SCHEDULE 5 – Data Processing & Information Security Addendum

 

INTEGRATION OF ATTACHED AGREEMENTS

For all service-specific standards (e.g., card acquiring, web payments, rolling reserve, fraud, indemnity, KYC, disputes, settlement timing, Open Banking integrations etc.), this Framework incorporates, mutatis mutandis, all operative legal, regulatory and commercial provisions of your provided agreement

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MONELIQ LIMITED | 25 Cabot Square, London, United Kingdom, E14 4QZ

Authorised Electronic Money Institution, regulated by FCA, License reference number 901056

Personal

Business

Terms and Conditions

Framework Agreement

Moneliq Limited (Company Number: 12213334) is a company registered in England and Wales, with its registered office at 25 Cabot Square, London, England, E14 4QZ.

Moneliq Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Electronic Money Institution under the Electronic Money Regulations 2011. Our FCA Firm Reference Number (“FRN”) is 901056.

You can verify our regulatory status by visiting the  FCA Register and searching for “Moneliq Limited” or by using our Firm Reference Number (FRN) 901056.

This Agreement is entered into for the Provision of Electronic Money, Payment Acquisition, Money Remittance, and Open Banking Services (AIS/PIS).

  1. Definitions and Interpretation

"Agreement": This framework and its schedules/annexes.

 

"Customer": The client contracting with Moneliq for one or more services under this Agreement.

 

"Services": E-Money issuance/redeeming, payment acquiring, money remittance, AIS, PIS (as described in Schedule 1).

 

"Open Banking": Access to AIS and PIS under the Payment Services Regulations 2017 (SI 2017/752).

 

"Acquirer" "Merchant" "Sub-Client" and other stakeholder terms use definitions as per all forms​ accompanied.

 

Interpretations, subdivision precedence, and other legal construction terms as set out in the attached agreements.​

  1. Scope of Services/Provision of Services

Moneliq will provide the Customer with one or more of the following, in the UK and EU:

 

E-Money Issue & Redemption: Issue, store, redeem electronic money in compliance with UK EMRs​. Important: Electronic money issued by Moneliq is not a deposit and is not protected by the Financial Services Compensation Scheme. Customer funds are safeguarded in compliance with the Electronic Money Regulations 2011 but will not benefit from FSCS protection.

 

Acquiring Services: Enable merchant acceptance and processing of payment transactions (cards or alternative methods)​.

 

Money Remittance: Facilitate payment orders and funds remittance for and on behalf of Customer.

 

Open Banking (AIS/PIS): Provide access to Account Information Services and Payment Initiation Services through Moneliq or as agent of a regulated provider.

 

Sub-clients: Where agreed, Moneliq may enable Customer’s connected sub-clients to utilise the Services, subject to due diligence and ongoing compliance oversight​.

 

  • 2.1 In consideration of payment by the Merchant of the Charges and Fees, Moneliq agrees, subject to the terms and conditions of the Agreement, to provide the Merchant with the Services as initially selected in the Application Documentation and amended, updated, supplemented and/or replaced from time to time in accordance with the Agreement. The Merchant can ask Moneliq for a copy of the Agreement at any time.

 

  • 2.2 Moneliq may from time to time provide the Merchant with Additional Services. Each Additional Service will be governed by the Additional Service Conditions applicable to it as well as the other terms and conditions of the Agreement. The Additional Service Conditions will be provided to the Merchant as and when they are applicable to the Merchant and the Agreement. The Merchant must pay the Charges and Fees (plus VAT, where applicable) relating to any Additional Service in accordance with the applicable Additional Service Conditions and the other parts of the Agreement.

 

  • 2.3 If the Merchant requires any additional product and/or service from Moneliq, which is not offered by Moneliq in the form of an Additional Service or other element of the Services, the Merchant shall issue a written request to Moneliq and, where Moneliq is willing to provide the relevant product and/or service, Moneliq shall propose a separate written agreement setting out the terms and conditions on which it is willing to provide such product and/or service ("Separate Agreement"). Unless and until such time as a Separate Agreement has been agreed and signed by or on behalf of the parties to govern Moneliq's provision of any additional product and/or service requested by the Merchant, Moneliq shall not be under any obligation to provide the relevant product and/or service. Once agreed and signed by or on behalf of the parties, each Separate Agreement will be entirely independent and separate from the Agreement.

 

  • 2.4 Consumer Protection and FSCS Disclosure

 

  • Moneliq is authorised by the Financial Conduct Authority (FCA) as an Electronic Money Institution. Funds held with Moneliq in connection with your e-money account, acquiring services, money remittance, or open banking activities are not deposits and do not earn interest. Your funds are not covered by the Financial Services Compensation Scheme (FSCS).

 

  • However, in accordance with the FCA’s safeguarding requirements, we protect your money by placing it into segregated safeguarding accounts with regulated credit institutions. This ensures that your funds remain separate from Moneliq’s own funds and are protected in the event of our insolvency.
  1. Term and Termination

This Agreement is effective from the date of execution, for an indefinite term, subject to initial/renewal periods as set out in the relevant Service Schedules.

 

Either party may terminate on not less than 2 months’ written notice (for ongoing services) or as per specific event/cause as detailed in attached forms (e.g. breach, insolvency, regulatory risk, or account inactivity).​

 

Moneliq may terminate or suspend some or all services immediately upon regulatory breach, security incident, non-payment, change to prohibited business, or where required by applicable law.

 

Change Control and Variation Process:

 

Moneliq may amend the terms of this Agreement, including changes to the services we provide, operational processes, or pricing, to reflect legal, regulatory, or business requirements.

 

We will provide you with at least 60 days’ written notice before any change takes effect, unless a shorter period is required by law or is necessary to address fraud prevention, security, or compliance matters. The updated terms will be made available on our website and, where applicable, communicated through your registered email or customer dashboard.

 

If you do not agree to the changes, you may terminate this Agreement free of charge before the effective date of the changes. Your continued use of our services after the effective date will constitute acceptance of the revised terms.

 

Any changes that do not affect your rights or obligations materially, such as minor editorial or administrative updates, may be made without prior notice but will be published promptly on our website.

  1. Fees and Payment

Fees, minimum monthly commitments, and tariffs for each Service are set out in the applicable Schedule(s) or Service Order Forms. Fees may include set-up, monthly, per-transaction, and volume-based charges.

 

Additional fees (e.g., chargebacks, card scheme penalties, investigation costs, reserves/rolling reserve, chargeback fees, fraud screening) may be applied as outlined.

 

Moneliq will invoice for Services in accordance with the agreed billing terms. All invoices must be paid within thirty (30) days of the invoice date. Interest on overdue amounts shall accrue at the rate specified in this Agreement or, if not stated, at the statutory rate under the Late Payment of Commercial Debts (Interest) Act 1998.

 

You may request redemption of your e-money balance at any time, subject to Moneliq’s published redemption procedures and any applicable fees set out in the relevant Service Schedule. Redemption requests will be processed promptly and no later than the end of the business day following receipt, unless further information is required to comply with legal or regulatory obligations.

  1. Service Obligations & Limitations

Customer must comply with all applicable laws, provide accurate information, maintain valid authorisations and licenses, and not use services for unlawful or restricted activities.

 

Moneliq reserves the right to:

 

Review and adjust its Fees or pricing structure at any time, by providing not less than sixty (60) days' written notice to the Customer.

 

Deduct or offset any unpaid or disputed sums, chargebacks, penalties, or other liabilities arising under this Agreement from settlement or payout amounts due to the Customer.

 

Require pre-funding, security deposits, or reserves (including rolling or capped reserves) where Moneliq reasonably determines that increased risk, exposure, or non-compliance may exist.

 

Suspend or withhold the settlement of funds in the event of suspected fraud, chargeback activity, a regulatory investigation, or a breach of any applicable regulatory, card network, or scheme rules.

 

All fees and charges are exclusive of VAT and any other applicable taxes, which shall be payable by the Customer in addition to the quoted amounts.

 

The Customer must comply with all applicable laws, regulations, and regulatory guidance, including but not limited to the Financial Services and Markets Act 2000, the Electronic Money Regulations 2011 (EMR), the Payment Services Regulations 2017 (PSR), the Data Protection Act 2018, the UK GDPR, and guidance issued by the FCA and relevant card schemes. The Customer shall provide accurate, complete, and up-to-date information to Moneliq at all times, maintain valid authorisations, licences, and approvals, and ensure that its business activities are lawful and properly disclosed. Services must not be used for any prohibited, unlawful, or restricted purposes as defined by Moneliq’s Acceptable Use Policy or relevant regulatory standards.

 

Acquiring and Card Acceptance Obligations

For the provision of card acquiring and acceptance services, the Customer must:

 

Adhere at all times to all applicable card scheme rules, network operating regulations, and any technical standards mandated by other scheme partners.

 

Not exceed published or permitted thresholds for chargebacks, fraud, or excessive refund activity.

 

Maintain appropriate fraud prevention, transaction validation, and dispute management controls.

 

Display scheme marks, acceptance logos, and required disclosures in accordance with card scheme and Moneliq branding requirements.

 

Maintain PCI DSS compliance and security of cardholder data, including not storing or transmitting sensitive authentication data except as permitted by scheme standards.

 

Notify Moneliq immediately of any suspected data breach, compromise, or unauthorised transaction activity.

 

Refrain from surcharge practices or transaction routing that breach scheme or legal requirements.

 

E-Money Services

For E-Money accounts and issuance:

 

The Customer acknowledges that all client funds are safeguarded in accordance with Regulation 20 of the EMR and are segregated from Moneliq’s own funds.

 

Funds held as e-money are not deposits and are not covered by the Financial Services Compensation Scheme (FSCS).

 

Interest or equivalent benefits are not payable on e-money balances.

 

The Customer retains a redemption right in accordance with the EMR, subject to Moneliq’s applicable redemption procedures, fees, and timeframes.

 

Any misuse of the e-money platform or breach of AML/CTF rules may result in immediate suspension or termination of the service.

 

Open Banking Services

For access to Open Banking services:

 

The Customer must obtain and maintain all consents and permissions from its users required under the PSR, FCA rules, and Moneliq’s technical and data sharing agreements.

 

Data access and processing must be clear, informed, and transparent, with user consent recorded and maintained.

 

All personal data processing must be conducted in full compliance with the Data Protection Act 2018, UK GDPR, and Moneliq’s Data Processing Agreement (DPA) and associated addendums.

 

The Customer must not misuse, retain, or share account information beyond the purpose authorised by the account holder or allowed by Moneliq.

 

Any data subject or withdrawal of consent notices must be communicated promptly to Moneliq.

 

Remittance and Cross-Border Payments

For remittance and money transfer services:

 

The Customer must comply with all AML/CTF obligations under the Money Laundering Regulations 2017 (as amended), including appropriate KYC and ongoing transaction monitoring.

 

The Customer must not process payments for sanctioned individuals or jurisdictions listed under UK, EU, OFAC, or UN sanctions lists.

 

All originator and beneficiary information must be accurate, traceable, and retained in accordance with FATF Recommendation 16 and UK requirements on wire transfers.

 

The Customer accepts that Moneliq may delay, suspend, or refuse transactions where required to comply with legal, regulatory, or risk management obligations.

 

General Limitations and Rights

Moneliq may:

 

Amend or withdraw any service in response to regulatory, scheme, or partner requirements, providing reasonable notice where practicable.

 

Suspend services, settlements, or account access if risk levels, breaches, or investigations arise.

 

Require enhanced due diligence (EDD), security deposits, or adjusted transaction limits based on risk profiling.

 

Share information with regulators, law enforcement, and scheme partners as required under applicable laws and regulatory obligations.

 

The Customer remains fully responsible for all acts, omissions, and compliance of its employees, agents, and sub-merchants (where applicable) in connection with the use of the Services.

 

  • 5A.2 Eligibility
  • The APP reimbursement provisions apply to Customers and End Users who meet the eligibility criteria under the applicable APP reimbursement rules (including consumers, micro‑enterprises and charities within the relevant thresholds).

 

  • A claim must relate to one or more In‑Scope Payment Systems payments made on or after 7 October 2024 and must be raised no later than 13 months after the date of the last payment made as part of the same scam.

 

  • 5A.3 Reimbursement and limits
  • Subject to clauses 5A.4 and 5A.5, where an eligible Customer or End User has fallen victim to an APP Scam in relation to an In‑Scope Payment Systems payment, Moneliq (acting as sending payment service provider) will reimburse the Customer for the Reimbursable Amount in accordance with the mandatory requirements set by the Payment Systems Regulator.

 

  • The Reimbursable Amount for any single APP Scam is subject to the maximum reimbursement cap in force under the APP reimbursement rules (currently £85,000 per claim, including all related payments that form part of the same scam) and any permitted excess which Moneliq may apply (currently £100 per claim).

 

  • Moneliq will normally make reimbursement within five Business Days of determining that the claim is in scope, subject to any permitted “stop‑the‑clock” pauses where additional information or co‑operation is required.

 

  • 5A.4 Customer standard of caution and co‑operation
  • To be eligible for reimbursement, the Customer and any End User must:
    • (a) take reasonable steps to protect themselves from scams, including reading and acting on any warnings presented in Moneliq’s channels at or before the time of payment;
    • (b) carry out basic checks where prompted (for example, contacting the payee using trusted contact details, and considering whether the payment request is consistent with their usual dealings); and
    • (c) report suspected APP Scams to Moneliq as soon as reasonably practicable and, in any event, within 13 months of the last payment related to the scam, and respond truthfully and promptly to Moneliq’s reasonable information requests.

 

  • Moneliq will have regard to FCA expectations and the Consumer Duty when assessing whether the Customer has met the required standard of caution, particularly where vulnerability may have had a material impact on their ability to protect themselves.

 

  • 5A.5 Exceptions to reimbursement
  • Moneliq may decline reimbursement where:
    • (a) the Customer or End User has acted fraudulently (first‑party fraud); or
    • (b) the Customer or End User has acted with gross negligence in failing to meet the standard of caution set out in clause 5A.4, taking into account applicable regulatory rules and guidance; or
    • (c) the payment is outside the scope of the APP reimbursement rules (including, without limitation, payments executed before 7 October 2024, payments outside the In‑Scope Payment Systems, or payments to an account owned or controlled by the Customer).

 

  • Moneliq will not treat a Customer as grossly negligent solely because they have fallen victim to a sophisticated scam. Moneliq will assess each case individually, considering all relevant evidence and any indicators of vulnerability.

 

  • 5A.6 Receiving‑PSP and “on‑us” payments
  • Where Moneliq acts as receiving payment service provider in relation to an APP Scam, Moneliq will meet any contribution obligations owed to the sending payment service provider under the applicable APP reimbursement rules.

 

  • Where both the sending and receiving accounts are held with Moneliq (“on‑us” payments), Moneliq will apply protections that are at least equivalent to those that would apply if the payment were executed over an In‑Scope Payment System, subject to any differences permitted under applicable regulation and guidance.

 

  • 5A.7 Process and complaints
  • Customers can raise an APP Scam claim using the usual incident reporting channels set out in Clause 14 and may submit a complaint under Clause 11 if dissatisfied with the handling or outcome of a claim.

 

  • If the Customer remains dissatisfied and is an eligible complainant, the Customer may refer the matter to the Financial Ombudsman Service in accordance with Clause 11.
  1. Due Diligence, AML, Sub-Clients

Moneliq (and, where applicable, its regulated partners will perform all necessary Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and sanctions screening checks on all Customers and, where applicable, on any of their sub-clients or associated entities. The Customer acknowledges that services are conditional upon successful completion of these checks, and Moneliq reserves the right to decline, restrict, or terminate services where onboarding requirements are not met or where ongoing monitoring identifies material risk.

 

The Customer shall fully cooperate with Moneliq and its partners in providing information, documentation, and evidence as requested at any stage for initial verification or ongoing monitoring, including but not limited to:

 

Corporate and ownership documentation identifying ultimate beneficial owners (UBOs).

 

Details of directors, controllers, and authorised representatives.

 

Proof of business activities, source of funds, and expected transaction volumes and counterparties.

 

Periodic reviews, sanctions and PEP (Politically Exposed Person) screening confirmations.

 

Transaction-level information requested for investigations or suspicious activity reviews.

Failure to provide accurate or timely information constitutes a material breach of this Agreement and may result in service suspension, delayed settlement, or termination as deemed necessary by Moneliq.

 

Customer Due Diligence and Sub-Client Responsibilities

Where the Customer introduces, onboards, or processes transactions for third parties (“sub-clients”, “merchants”, or “end users”), the Customer is solely responsible for performing adequate due diligence and risk assessment on each such sub-client and maintaining full visibility and control over their activities. The Customer must:

 

Implement and maintain AML, CTF, and sanctions policies, systems, and controls proportionate to its business and risk profile.

 

Identify and verify each sub-client’s legal identity, ownership, and business nature before permitting access to any payment, e-money, or acquiring service.

 

Conduct ongoing monitoring of sub-clients’ transactions, ensuring continuous compliance with AML and fraud prevention standards.

 

Ensure sub-clients do not use the services for illegal, high-risk, or prohibited activities as defined under Moneliq’s Acceptable Use Policy and applicable FCA/AML rules.

 

Retain records of all KYC and transactional information for a minimum of five (5) years or longer where required by law.

 

Immediately report to Moneliq any suspicious, unusual, or high-risk activity and cooperate with requests for supporting documentation or data.

 

Monitoring, Reporting, and Cooperation

Moneliq and its regulated partners will perform ongoing transaction monitoring, sanctions checks, and screening of all transactional activity to detect, prevent, and report suspicious transactions in line with the Money Laundering Regulations 2017 (as amended) and FCA supervisory expectations. The Customer acknowledges and agrees that:

 

Moneliq may delay, freeze, or decline transactions where enhanced due diligence or investigation is required.

 

Certain information may be disclosed to regulatory or law enforcement authorities where required under applicable laws.

 

Moneliq may impose enhanced due diligence (EDD), limit transactions, or adjust settlement timing for higher-risk customers or sub-clients.

 

Any failure to respond to AML, sanctions, or fraud-related information requests within the specified timeframe may result in the immediate suspension or termination of services.

 

Audit and Verification Rights

Moneliq reserves the right to audit or review the Customer’s AML and compliance procedures, either directly or through appointed representatives, at reasonable intervals. Such reviews may include inspection of KYC records, monitoring reports, and control procedures relating to sub-clients. The Customer shall grant timely access to all requested materials and cooperate fully with any audit process.

 

Where deficiencies or policy breaches are identified, Moneliq may issue remediation requirements that must be completed within a specified period. Failure to remedy such issues constitutes a material breach of this Agreement and may lead to service suspension or termination.

 

The parties acknowledge that Moneliq remains ultimately responsible for maintaining compliance with regulatory obligations under the EMR, PSR, and MLR, and that cooperation with its due diligence and oversight functions is a strict condition of continued service provision.​

  1. Liability and Indemnity

Each party’s liability under this Agreement is subject to the exclusions and limitations of liability set out within this clause and, where applicable, within the individual Service Schedules or Order Forms. Liability provisions apply collectively across all Services provided by Moneliq and its regulated partners, including (without limitation) acquiring, e-money, Open Banking, and remittance services.

 

Exclusions and Non-Limited Liabilities

Nothing in this Agreement excludes or limits either party’s liability for:

 

Death or personal injury caused by its negligence or that of its employees or agents.

 

Fraud, fraudulent misrepresentation, or wilful misconduct.

 

Breach of any regulatory obligation or indemnity provided under this Agreement.

 

Any other liability that cannot lawfully be excluded or limited under applicable law.

 

Except as set out above, Moneliq shall not be liable for:

 

Any indirect, special, incidental, punitive, or consequential loss;

 

Loss of business, revenue, contracts, customers, profits, opportunities, anticipated savings, or goodwill;

 

Losses resulting from downtime, interruption, data corruption, or transmission delays;

 

Any obligation, fine, or loss arising from the Customer’s failure to comply with scheme rules, AML/CTF obligations, data protection laws, or instructions from Moneliq or its partners.

 

Financial Caps on Liability

For all other claims not excluded above, Moneliq’s maximum aggregate liability to the Customer in any twelve (12) month period shall not exceed the greater of:

 

The total Fees paid by the Customer to Moneliq for the relevant Service during the twelve (12) months immediately preceding the event giving rise to the claim; or

 

The minimum statutory cap required under applicable regulation or FCA guidance relevant to the Service type (acquiring, e-money, or payment services).

 

Each Service Schedule may specify separate caps, thresholds, or risk-weighted amounts in accordance with the operational and regulatory context. Where multiple Services are provided, the cap applies on a per-Service basis unless expressly stated otherwise in writing.

 

Where Moneliq processes transactions via third-party networks, partners, scheme providers, or APIs, Moneliq shall not be liable for any losses, delays, or failures caused by those third parties, provided Moneliq has acted with reasonable care and diligence.

 

Customer Indemnities

The Customer shall indemnify and hold harmless Moneliq, its officers, affiliates, employees, and partners from and against any and all claims, losses, damages, penalties, costs, or expenses (including reasonable legal and investigation costs) arising out of or connected with:

 

Breach by the Customer or any of its sub-clients of this Agreement, Service Schedules, or scheme/network rules;

 

Failure to perform required AML, CTF, or sanctions compliance obligations;

 

Any fraudulent, unlawful, or improper use of the Services or payment infrastructure;

 

Any data breach, chargeback, or misuse of confidential information;

 

Any regulatory or card scheme fines, penalties, or enforcement actions attributable to the Customer’s acts or omissions;

 

Any third-party claim arising from the Customer’s use or provision of Services to its own clients, end-users, or sub-merchants.

 

Mitigation and Aggregation

Each party shall take all reasonable steps to mitigate any loss or damage which it may suffer under this Agreement. Claims arising from the same or connected events shall be aggregated and treated as one claim for the purposes of calculating limits or caps under this clause.

 

Force Majeure and System Dependencies

Moneliq shall not be liable for any delay, suspension, or failure in performance resulting from strikes, labour disputes, industrial actions, acts of God, war, terrorism, embargo, regulatory actions, disruption or failure of telecommunications or banking networks, third-party provider failures, or any event beyond its reasonable control.

  1. Data Protection & Confidentiality

Both parties agree to comply with all applicable Data Protection Legislation, as defined in the Data Protection Act 2018 (“DPA”), the UK General Data Protection Regulation (“UK GDPR”), and any additional provisions in the relevant service schedules. Each party shall implement appropriate technical and organisational measures to safeguard personal data against unauthorised or unlawful processing, loss, destruction, or damage, in accordance with the standards required by law and guidance issued by the Information Commissioner’s Office (ICO).

 

Both parties acknowledge that any proprietary, commercially sensitive, or confidential information disclosed during the course of this Agreement must be kept strictly confidential and not used or disclosed except as necessary for the performance of this Agreement. Disclosure is permitted only where required by applicable law, regulation, or law enforcement authorities, including but not limited to obligations under the Financial Conduct Authority (“FCA”), money laundering regulations, or other regulatory directives.

 

Each party agrees not to disclose, publish, or otherwise make available any information belonging to the other party to any third party without prior written consent, except as may be required by law or regulatory mandate. All staff, contractors, and agents involved in the delivery of services under this Agreement shall be bound by equivalent confidentiality and data protection obligations.

 

Both parties shall take all reasonable steps to ensure the secure processing and transmission of data, utilizing industry-standard encryption, restricted access, monitoring, and incident management procedures. In the event of any actual or suspected data breach affecting personal data, proprietary or sensitive information shared under this Agreement, the affected party shall:

 

Notify the other party promptly and, in any event, within 24 hours of becoming aware of the incident.

 

Cooperate fully to investigate, mitigate, and remediate the breach, including fulfilling any statutory reporting obligations to the ICO and other relevant authorities.

 

Support the other party with any required regulatory or customer communications arising from the breach.

 

Upon expiration or termination of this Agreement, each party shall, as directed by the disclosing party, securely return or destroy all confidential information and personal data provided under this Agreement, save where retention is required for legal or regulatory compliance or legitimate business purposes.

  1. Notices

All notices, requests, consents, approvals, and other formal communications under or in connection with this Agreement must be in writing and delivered by hand, pre-paid recorded delivery, or sent by email to the addresses or contacts specified in the applicable Order Form, or such other contact details as either party may notify to the other in writing from time to time.

 

Notices shall be deemed to have been received:

 

if delivered by hand, on signature of a delivery receipt or at the time the notice is left at the correct address;

 

if sent by pre-paid recorded delivery or courier, at 9:00 a.m. on the second business day after posting;

 

if sent by email (to the designated business contact address), at the time of transmission as recorded by the sending party’s system, provided that no error message or notification of non-delivery has been received.

 

Communications between the parties relating to the operational performance of services, incident management, security notifications, or any matter concerning data protection, financial crime, or compliance obligations must be sent to the relevant designated compliance, risk, or operations contacts notified by each party in writing.

 

All regulatory or legal correspondence, including those from the FCA, HMRC, law enforcement, or data protection authorities, must be promptly forwarded to the receiving party’s compliance contact and acknowledged in writing within two business days.

 

Each party shall maintain appropriate records evidencing its communications under this Agreement and ensure that such records are retained for a minimum period of six (6) years or as required by applicable law and regulation.

 

Either party may update its notice details (including contact emails and postal addresses) by providing written notification to the other party, which will take effect five (5) business days after receipt, unless agreed otherwise in writing.

 

Where electronic signatures or communications are used, such communications shall be deemed duly executed and admissible as evidence in any legal or regulatory proceedings, provided they comply with applicable electronic communications and evidentiary rules in the United Kingdom.

  1. Delegation and Subcontracting

Moneliq may delegate or outsource certain operational, technical, or support functions to carefully selected third‑party providers, including technology partners, payment processors, banking partners, and open banking gateway providers. Any such arrangement will be managed in accordance with applicable regulatory requirements set out by the Financial Conduct Authority (FCA) and industry standards on outsourcing and operational resilience.

 

Where regulated activities or critical or important functions are outsourced, Moneliq retains full responsibility for the performance, compliance, and oversight of those service providers. Moneliq ensures that all delegated parties operate under written agreements that clearly define their obligations, maintain equivalent levels of security, confidentiality, and data protection, and allow for effective monitoring and audit.

 

All subcontracting and delegation arrangements are subject to due diligence, risk assessment, and ongoing performance review. Moneliq does not transfer its regulatory responsibilities under the Electronic Money Regulations 2011 or the Payment Services Regulations 2017 through outsourcing, and remains directly accountable for compliance with all applicable laws, customer protections, and regulatory reporting duties.

 

Moneliq may also rely on third‑party partners for open banking interfaces and API connectivity; however, all such integrations are subject to strict access controls, contractual safeguards, and continuous monitoring to ensure integrity, operational continuity, and security of customer data.

  1. Complaints Handling and Customer Redress

Moneliq is committed to providing high-quality services and resolving any concerns promptly and fairly. If you are dissatisfied with any aspect of our e-money, acquiring, money remittance, or open banking services, you may submit a complaint through any of the following channels:

 

  • Email: complaints@moneliq.com
  • Post: Complaints Department, Moneliq Ltd, 25 Cabot Square, London, England, E14 4QZ.
  • Online: Through your customer portal or the contact form on our website

 

We will acknowledge your complaint promptly and aim to issue a final response within 15 business days. In exceptional circumstances, where a full response cannot be provided within that timeframe, we will inform you of the reason and issue a final response within 35 business days, in accordance with the FCA’s DISP rules.

 

If you are an eligible complainant and are not satisfied with our response, you have the right to refer your complaint to the Financial Ombudsman Service (FOS) free of charge within six months of our final response. The FOS can be contacted at:

 

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

 

Telephone: 0800 023 4567

 

Website: www.financial-ombudsman.org.uk

 

We continuously review complaints to identify potential improvements to our products and services in line with our regulatory obligations and commitment to fair customer outcomes.

 

  1. Safeguarding of your Funds

Moneliq safeguards customer funds in accordance with the Electronic Money Regulations 2011. All funds received from customers in exchange for electronic money, or for the provision of payment services associated with e-money, are placed without delay into designated safeguarding accounts held with one or more authorised credit institutions or partner banks that meet FCA standards for safeguarding arrangements.

 

Moneliq maintains separate safeguarding accounts to ensure that safeguarded funds are kept distinct from its own operating funds and any other third-party monies. These accounts are subject to daily reconciliation to ensure the amount held matches the total value of customers’ e-money and payment funds. Any shortfall identified through reconciliation is corrected immediately, and any surplus is removed to maintain compliance with the safeguarding obligations under Regulation 21 of the EMRs.

 

The safeguarding process ensures that, in the event of Moneliq’s insolvency, customers’ funds remain protected and are distributed to them ahead of other creditors, following administration or liquidation procedures set out by the relevant insolvency legislation.

 

Our partner banks are subject to ongoing due diligence, contractual assurance, and periodic reviews to confirm that their safeguarding arrangements and account structures are operated in line with applicable FCA guidance and regulatory expectations.

 

Moneliq’s safeguarding records include detailed reconciliation logs, bank confirmations, and transaction journals maintained in compliance with regulatory recordkeeping requirements.

  1. Record Retention Periods

Moneliq maintains comprehensive records in accordance with the Money Laundering Regulations 2017 (as amended) and the FCA’s Senior Management Arrangements, Systems and Controls sourcebook (SYSC). These records include, but are not limited to, customer identification (KYC) documentation, transaction data, communications, risk assessments, and any other information relevant to our regulated activities.

 

All customer and transaction records are retained for a minimum period of five years from the date of the end of the business relationship or the completion of the transaction, whichever occurs later. Where required by law or regulatory instruction, Moneliq may retain certain records for up to six years or longer to meet legal, accounting, or investigative obligations.

 

Records are stored securely in electronic form to ensure integrity, confidentiality, and accessibility for regulatory review. Moneliq ensures that data retention and deletion practices comply with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  1. Security Details and Incident Handling

Moneliq employs robust information security and fraud prevention measures designed to protect customer data, safeguard transactions, and ensure the integrity of our payment, e-money, acquiring, remittance, and open banking services. Our security framework is aligned with industry standards and regulatory expectations, including the FCA’s requirements, the Payment Services Regulations 2017, and applicable ISO 27001 information security principles.

 

All sensitive data transmitted between customers, merchants, and Moneliq systems is encrypted and stored securely. Access to systems handling personal or financial information is strictly controlled, monitored, and subject to strong authentication mechanisms. Regular vulnerability assessments and penetration testing are conducted to identify and mitigate potential risks within Moneliq’s IT infrastructure and open banking APIs.

 

Customers must take reasonable precautions to keep their security credentials, API keys, or account access details confidential and must notify Moneliq immediately of any actual or suspected unauthorised access, fraud, or system compromise. Reports can be made to security@moneliq.com or via the in-app support feature.

 

In the event of a security or payment-related incident, Moneliq will investigate promptly, take necessary remedial measures, and, where required, inform affected customers and relevant authorities in accordance with regulatory reporting obligations under the FCA and the UK GDPR. This includes any suspected or actual Authorised Push Payment scam affecting your account, which you must report to us as soon as possible in accordance with Clause 5A.

 

Moneliq also operates an incident management policy ensuring all detected or reported threats are logged, reviewed, and resolved in line with our business continuity and operational resilience framework.

  1. Consumer Duty

Moneliq is committed to delivering good customer outcomes in accordance with the Financial Conduct Authority’s (FCA) Consumer Duty. This Duty underpins how Moneliq designs, delivers, and monitors its products, services, and customer communications across all areas of its business, including e-money issuance, merchant acquiring, money remittance, and open banking activities.

 

Moneliq ensures that products and services are designed to meet the needs, characteristics, and objectives of the identified target market, and that customers receive fair value throughout the entire relationship. The company proactively considers the diverse needs of its customers, including those in vulnerable circumstances, and takes steps to avoid foreseeable harm.

 

All customer interactions, whether marketing materials, website content, contractual documentation, or operational communications, are fair, clear, and not misleading. Moneliq aims to provide customers with the information, tools, and support they need to make effective, informed decisions about their use of Moneliq products and services.

 

To fulfil its Consumer Duty obligations, Moneliq:

 

Designs and reviews its products to ensure they offer fair value and meet identifiable customer needs.

 

Conducts ongoing assessments of customer outcomes, supported by management information, complaints analysis, and customer feedback.

 

Ensures pricing, fees, and charges are transparent and proportionate to the benefits customers receive.

 

Provides customers with accessible and timely support across all channels, ensuring issues are resolved promptly and fairly.

 

Maintains a culture of accountability and responsibility at all levels of the organisation, with governance structures that oversee the delivery of good customer outcomes.

 

Incorporates Consumer Duty considerations into product governance, risk management, and compliance monitoring frameworks.

 

Regularly reports to senior management and the Board on customer outcome metrics and takes remedial action when gaps or risks are identified.

 

Designing and operating fraud‑prevention, warning and APP Scam reimbursement processes that are consistent with regulatory requirements and support good customer outcomes.

 

Moneliq’s approach to Consumer Duty is embedded in its day-to-day operations and decision-making. The firm continually strives to enhance transparency, trust, and value in every aspect of its customer relationships.

  1. Governing Law and Jurisdiction

This Framework Agreement, together with all Schedules, Annexes, and any related documents or arrangements entered into pursuant to it, shall be governed by and construed in accordance with the laws of England and Wales.

 

The parties irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute, controversy, or claim (including non-contractual disputes or claims) arising out of or in connection with this Agreement, its subject matter, or formation.

 

Before initiating any legal proceedings, the parties shall first use best endeavours to resolve any dispute or disagreement through good faith negotiations between their respective senior management representatives. If such negotiations fail to resolve the matter within thirty (30) days of written notice of dispute, either party may refer the matter to mediation under the Centre for Effective Dispute Resolution (CEDR) Model Mediation Procedure before resorting to litigation, unless urgent injunctive, equitable, or regulatory relief is required.

 

Nothing in this clause shall prevent either party from seeking interim or injunctive relief, or from fulfilling any mandatory reporting or co‑operation obligation with a regulator, supervisory authority, or law enforcement agency, including but not limited to the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), Information Commissioner’s Office (ICO), or HM Revenue & Customs (HMRC).

 

The parties acknowledge that the services provided under this Agreement, including acquiring, e-money issuance, open banking, and remittance, are subject to applicable UK and international regulatory frameworks. Accordingly, where regulatory interpretation or intervention is required, the parties shall comply with all directions or determinations made by the relevant competent authority.

 

Each party waives any objection to proceedings in the courts of England and Wales on the grounds of inconvenient forum or any similar basis and agrees that any judgment or order of such courts shall be final and binding, subject only to rights of appeal under English law.

 

This clause shall survive termination or expiry of the Agreement.

  1. Schedules

SCHEDULE 1 – Service Description (by type: e-money, acquiring, remittance, open banking)

SCHEDULE 2 – Fees and Volume Charges

SCHEDULE 3 – Conflicts & Precedence (Order form, then Service Schedules, then Framework)

SCHEDULE 4 – Sub-client/Agency/End User Terms

SCHEDULE 5 – Data Processing & Information Security Addendum

 

INTEGRATION OF ATTACHED AGREEMENTS

For all service-specific standards (e.g., card acquiring, web payments, rolling reserve, fraud, indemnity, KYC, disputes, settlement timing, Open Banking integrations etc.), this Framework incorporates, mutatis mutandis, all operative legal, regulatory and commercial provisions of your provided agreement

MONELIQ LIMITED | 25 Cabot Square, London, United Kingdom, E14 4QZ

Authorised Electronic Money Institution, regulated by FCA, License reference number 901056