A practical guide to the data, reconciliation, governance and evidence EMIs need to run safeguarding day to day under CASS 15. Produced by Kani and Moorwand
For EMIs, the challenge goes beyond understanding the regulatory requirements. Safeguarding has to work across live programmes, processors, banking partners, currencies and payment flows, while producing a position that can be reconciled, reviewed and evidenced every reconciliation day.
Safeguarding in practice, produced by Kani and Moorwand, examines what that operating model looks like.
Drawing on Moorwand’s experience as a regulated EMI and programme operator and Kani’s expertise in payments data, reconciliation and reporting, the guide explores the controls, records and oversight needed to make safeguarding sustainable day to day.
What CASS 15 requires
The strengthened regime sets specific, repeatable obligations: internal and external reconciliations on every reconciliation day, the D+1 comparison under the standard method, identification and remediation of shortfalls, monthly REP027 returns, and the records behind the CASS resolution pack. Firms in scope of SUP 3A must also arrange an annual independent safeguarding audit.
Inside the guide
The paper looks at safeguarding from the point where regulation meets daily payment operations, including:
- The EMI reality: how settlement timing, FX, chargebacks, refunds, partners, programmes and currencies complicate the safeguarding position
- The data layer: why dependable daily reconciliation starts with complete, consistent source data
- The safeguarding operating model: ownership, internal and external reconciliations, shortfalls, reporting, retrieval and audit
- Safeguarding through partners: oversight, contractual protections, data rights and independent reconciliation where operational activity is delegated
- Where safeguarding breaks: from late data and spreadsheet dependency to missing evidence and reconstructed monthly returns
- What good looks like: ten characteristics of a safeguarding model designed to operate consistently
- Practical readiness: a 12-point checklist firms can use to test their current safeguarding operation
Two perspectives on the same control
Safeguarding sits across regulation, finance, operations and data, so the guide approaches it from both sides of the operating model.
Moorwand contributes the perspective of a regulated EMI running safeguarding within live payment operations, including financial governance, programme oversight and regulatory compliance.
Kani contributes the payments data, reconciliation and reporting perspective: how the underlying records are brought together, tested, investigated and retained as evidence.
The result is a practical guide focused on what firms need to make work day to day.
Who is the guide for?
The guide is designed for people responsible for safeguarding across e-money and payments businesses, including compliance and safeguarding leads, finance directors and finance teams, operational leaders, senior managers, programme owners and teams responsible for reconciliation, reporting and safeguarding data.
About Moorwand
Moorwand is a London-based payments solutions provider and FCA-authorised electronic money institution, offering issuing, BIN sponsorship, digital banking and compliance services.
Its contribution to this guide draws on the experience of CFO Olga Dodul, who leads Moorwand’s financial reporting, regulatory compliance and safeguarding functions, and Regulatory Compliance Manager Tony Forbes, who leads its second-line regulatory compliance function.
Together, their perspectives bring practical experience of financial governance, programme complexity, safeguarding controls and regulatory oversight to the paper.
About Kani
Kani is a payments data platform that makes reconciliation and regulatory reporting fast, accurate and audit-ready. Its contribution to this guide draws on the experience of CEO and founder Aaron Holmes and Head of Strategic Solutions Andrew Wingfield, bringing the perspective of the data, reconciliation and evidence layer that safeguarding depends on.
