Viola Money (Europe) Limited

Limits on the record

• Requirements (1 of 2)

  Pursuant to regulation 11(1) of the EMR, the Authority has decided to vary the authorisation granted to VMEL by imposing with immediate effect the following requirements: a) VMEL must not without the prior written consent of the Authority in any way dispose of, deal with, transfer or diminish the value of any funds or assets, whether held in the United Kingdom or elsewhere and whether safeguarded or otherwise, that: i. it holds that have been received in exchange for, or are held in respect of, electronic money that has been issued; ii. comprise sums received from, or for the benefit of, a payment service user for the execution of a payment transaction and/or sums received from a payment service provider for the execution of a payment transaction on behalf of a payment service user; iii. comprise funds held on behalf of any other individual or entity, whether in relation to regulated or unregulated business; or iv. is held in its own accounts or accounts that it holds on behalf of its customers, agents or any third party (i)-(iv) prevent VMEL from dealing, transferring, disposing of or diminishing the value of the specified funds or in any way, regardless of the sum or value involved and/or whether in the ordinary course of business, without the Authority’s prior written consent b) Without prejudice to (a) above, VMEL must not in any way dispose of, deal with or diminish the value of any of its funds or assets whether in the United Kingdom or elsewhere without the prior written consent of the Authority. This requirement does not prohibit VMEL from dealing with or disposing of any of its assets in the ordinary and proper course of business provided that no such dealings or disposals are for a sum or value in excess of £5,000 whether as a single transaction or as a combination of related transactions. Transactions above £5,000 shall not be permitted without the prior written consent of the Authority; c) VEML must notify the Authority in writing within 24 hours of the issue of this notice of all the details of all accounts it holds including: (i) the institution at which they are held; (ii) account numbers and sort codes; (iii) balances; and (iv) which (if any) are safeguarding accounts. Further, the notification must detail any sums which it is required to safeguard pursuant to the EMR or PSR which are not currently held in a designated safeguarding account. This should include details of the account and current balance and in the event of comingling of funds, the notification should specify how much of a given balance comprises funds which should be safeguarded. For the avoidance of doubt these notification requirements apply to the details and balances of any account VMEL holds (either on its own account or on behalf of any customer, agent or third party); d) VMEL must not carry out any of the activities for which it is authorised pursuant to either the EMR or PSR (including, for the avoidance of doubt, carrying out any activities through its agents), namely: i. Services enabling cash placement on a payment account; ii. Services enabling cash withdrawals from a payment account; iii. Execution of payment transactions (not covered by a credit line); iv. Execution of payment transactions (covered by a credit line); v. Issuing payment instructions or acquiring payment transactions; vi. Money remittance; and vii. Issuing Electronic Money Except that VMEL may continue to hold assets or funds specified in (a) above, subject to that requirement and to (b)

• Requirements (2 of 2)

  e) VMEL must not take on any new agents; f) A director of VMEL must provide to the Authority on a weekly basis an attestation of compliance with (a)-(b) and (d)-(e) above. This should be provided no later than 12:00pm each Friday and should be provided with such bank statements as the Authority may request; g) VMEL must – within 48 hours of the issue of this notice - set out in a prominent place on all its websites, and must email to all of its customers, a statement that it is no longer permitted to conduct any authorised activities and, further, notifying customers that it is not currently permitted to distribute any funds. VMEL must also provide the notification to all its agents and direct that the agent notifies customers accordingly. The wording and format of this announcement and notification is to be approved by the Authority prior to being placed on the website or sent and VMEL must provide written confirmation to the Authority immediately upon complying with the terms of this requirement (confirmation should include a list of agents and/or customers to whom it was sent); and h) VMEL must secure all books and records and preserve information and systems relating to its authorised activities and must retain these in a form and at location to be notified to the Authority in writing within 48 hours of the issue of this notice such that they can be provided to the Authority, or to a person named by the Authority, promptly on its request.