Security policy

Security For Expenses Ltd is a Small Payment Institution (SPI) registered with the FCA and supervised by HMRC under anti-money laundering regulations (AMLR). The Company takes security very seriously and has worked to develop systems and procedures that minimise the risk of fraud, money laundering and the financing of crime and terrorism while maintaining transparency and ease of use for our clients.

Our Service is tailored to specific circumstances that fall into five categories of Transaction:

  1. Security under the Party Wall etc. Act 1996
  2. Security under a Licence for Access or Alterations
  3. Contract monies and retentions under a Building Contract
  4. Bonds
  5. Commercial Rent Deposits

In cases where funds are held as security and then returned to the same bank account from which they were received there is no payment to a third party. This is not a Payment Transaction for the purposes of The Payment Services Regulations 2017 and such Transactions should not be included in the Company’s annual FSA057 (Payment Services Directive Transactions) report to the FCA.

Clients do not have access to funds deposited with the Company. Only the Company can make payments out of client accounts. Payments are made only under specific contract terms on written direction by persons authorised under that contract and to persons specified in that contract.

1. Money Laundering and Financial Crime

  • The Company’s approach to money laundering and financial crime is set out in our Anti-Money Laundering Policy

2. Physical Security Measures

  • Physical data and records are not kept on the premises at the Company’s office.

3. Payment Process

  • All Transactions are by direct bank transfer between United Kingdom bank accounts. Under no circumstances are cash deposits accepted or cash payments made.
  • We verify that funds received into the Company’s account originated from the account advised to us by the PGS.
  • If funds are transferred by BACS, CHAPS or another banking intermediary service and the Company’s bank cannot confirm the originating account we require evidence from the PGS that funds were remitted from the confirmed account.
  • Payments are made only by a member of the Company’s Executive Management Board. No automated payments can be made from the Company’s client accounts.
  • Payments are made into accounts that have been confirmed only after KYCDD has been completed.
  • On receiving instructions to make a payment an initial payment of £10 will be made into the confirmed payee account. When the payee confirms safe receipt of the initial payment the balance will be transferred.

4. Transaction Analysis

  • Each Transaction is controlled at every stage by one of the Executive Management Board. It is checked against the Contract Schedule to ensure that payments are made only in accordance with the procedures applicable.
  • Any circumstances arising in the course of a Transaction or an application to the Company for a Transaction falling outside the normal conditions outlined in this Policy Statement shall be immediately communicated to a Director who will assess the implications and, if required, update this Policy Statement accordingly.
  • All major incidents will be reported within four hours of being detected to the FCA under Regulation 99 of the Payment Services Regulations 2017 in line with the European Banking Authority Guidelines on Operational and Security Risks under PSD2 on incident reporting.
  • To comply with HMRC requirements, details of all Transactions will be kept for a minimum period of five years after the Transaction is closed.

5. Staff Training

  • The Executive Management Board and staff meets no less than once each year to review and discuss cases that have arisen in the previous year.