This Policy establishes the principles, operational procedures and control mechanisms designed to ensure the protection of funds received from users for the issuance of electronic money and the provision of payment services by UNNAX REGULATORY SERVICES EDE, S.L.U. (“UNNAX” or the “Entity”).
Compliance with this Policy ensures that clients’ funds are segregated from the Entity’s own assets and protected against claims from third-party creditors, in accordance with Law 21/2011 of 26 July on electronic money and Royal Decree-Law 19/2018 of 23 November on payment services, as well as their implementing regulations.
This document applies to third-party funds managed by UNNAX in its capacity as an electronic money institution.
The Entity adopts, as its safeguarding method, the deposit of funds in segregated bank accounts (Method 1) held with authorized credit institutions.
Accordingly:
To ensure that issued electronic money liabilities are adequately covered for safeguarding purposes, the Entity implements the following protocol:
If the Entity detects any discrepancy, an immediate root cause analysis will be conducted.
If insufficiency of funds is confirmed:
The Entity maintains a due diligence policy for selecting custodian banks in order to mitigate counterparty risk.
The list of active depositary institutions is detailed in Annex I and updated periodically by the Risk and Compliance Department.
The Finance and Operations departments are responsible for executing the safeguarding process.
The Risk and Compliance department supervises reconciliations and monitors compliance with solvency ratios on a monthly basis.
Internal Audit conducts an annual review of the safeguarding system and issues a report regarding the adequacy of controls and accounting accuracy submitted to the Bank of Spain.
In accordance with transparency requirements, UNNAX informs its clients through service agreements and its website about the safeguarding methods used and the identity of the institutions where client funds are held.
This Annex details the credit institutions where UNNAX currently holds safeguarded client funds. This list is dynamic and may be updated without modifying the main body of the Policy.