Universal Partners FX Ltd is authorised by the Financial Conduct Authority (FCA) as an Authorised Payment Institution (“API”) under the Payment Services Regulations 2017. As an authorised Firm, we are required to safeguard client funds by holding those funds in a segregated client account, separate from our own business accounts.

These accounts are designated as Safeguarded accounts and protected in the event of our insolvency and are also protected from any interest in, recourse against, or right of set-off from the financial institution where UPFX holds client funds.

Safeguarding is the obligation to identify and keep client funds segregated and protected from all other funds that the business may receive for the purpose of the provision of a payment service, segregating the funds as soon as they are received and moving the funds to a safeguarding account, or if the funds for a payment transaction are still held by the Firm after receipt. The obligation commences as soon as funds are identified as relevant funds and are received by UPFX (and stops when funds are remitted to and received by the clients’ recipient).

For a Payment Services institution, relevant funds are deemed as follows: Funds received from, or for the benefit of, a payment service user for the execution of a payment transaction; and funds received from a payment service provider for the execution of a payment transaction on behalf of a payment service user (the client). The funds are no longer deemed relevant once the Firm has remitted them to the recipient and the Firm can reasonably assume that the funds have reached the recipient's bank account.

Where UPFX can identify that unclaimed or unallocated funds have been received from a client to execute a payment transaction then these funds will be identified as relevant funds and safeguarded accordingly.

Funds that are not deemed relevant include the following:

  • Deposits for forward contracts, until they are allocated for a payment instruction following the forward contract being settled.

  • Margin calls on forward contracts until they are allocated for a payment instruction following the forward contract being settled.

  • Unclaimed or unknown funds not related to the payment service – Where UPFX can identify that unallocated funds have not been received from a client to execute a payment transaction, then UPFX will use reasonable endeavours to identify the customer to whom the funds relate but these will not be considered relevant funds for the purposes of regulation 23 of the PSRs 2017.

Where client funds are subject to safeguarding, that means that client funds benefit from the arrangements put into place to protect these funds in the event of insolvency of the Firm. Client funds are held in segregated accounts and moved to safeguarding accounts if the monies are still with the Firm on the day after receipt.

Our safeguarding obligations are outlined in Chapter 10 of the FCA Approach document which can be found here


  • What happens if funds get lost in transit i.e., we send them out, but funds don’t arrive as expected? What processes do we have in place to monitor this?
  • If funds do not arrive within expected time frames a ‘trace’ can be placed by our Operations Team to track the progress of the payment. Occasionally payments can be delayed by intermediary banks and in extreme cases may be returned if the bank account details are deemed invalid. Our approach to incorrectly executed transactions are outlined in our terms and conditions in sections 14.2, 14.3 and 14.4 which can be located here.
  • If Universal Partners FX were to go out of business, how would our clients get their money back?
  • Are Universal Partners FX clients covered under the Financial Services Compensation Scheme (FSCS)?
  • How does an API differ from a bank?
  • What is the difference using Universal Partners FX and the Currency Cloud for payment services?
  • How can our customers make a complaint?
Talk to one of our Finance Foreign Exchange Experts today