FCA Announces Liquidation of Small Payment Institution PPS Money; Customer Funds Unprotected

Key Takeaways

• Premier Payment Solutions Ltd (trading as PPS Money and MTBS), a UK small payment institution, entered voluntary liquidation on September 10, 2026, and joint liquidators from BTG Begbies Traynor have been appointed.
• Customer funds are not covered by the Financial Services Compensation Scheme (FSCS), and small payment institutions are not required to safeguard funds under the Payment Services Regulations 2017.
• Compliance teams at firms with exposure to PPS Money, whether as customers, counterparties, or agent networks, should assess their positions promptly.

Deep Dive

Premier Payment Solutions Ltd (trading as PPS Money and MTBS), a UK small payment institution, entered voluntary liquidation on September 10, 2026, and joint liquidators from BTG Begbies Traynor have been appointed. Customer funds are not covered by the Financial Services Compensation Scheme (FSCS), and small payment institutions are not required to safeguard funds under the Payment Services Regulations 2017. Compliance teams at firms with exposure to PPS Money, whether as customers, counterparties, or agent networks, should assess their positions promptly.

The FCA states that PPS Money remains registered and must continue to comply with FCA rules during liquidation. The firm provided money-remittance services, primarily to money service businesses (MSBs) making cross-border payments, and operated through a network of FCA-registered agents. Directors placed the firm into voluntary liquidation after concluding it could no longer trade because of significant financial difficulties. The joint liquidators, Bai Cham and Gary Shankland, are responsible for assessing customer claims and distributing funds where possible. The FCA says it is liaising with them and will take any necessary actions to seek the best outcome for consumers.

The most significant feature of this case is the lack of protection. The FSCS does not cover payment services, and small payment institutions are not required to safeguard customer funds under the PSRs. Customers are therefore likely to be unsecured creditors, and recovery is uncertain. The notice gives no figures for customer balances or expected recoveries, and no claims deadline or bar date. Customers are told to monitor the liquidators' updates, and the timeline for returning funds is unknown. The FCA also warns that claims management companies and law firms usually add little value for most customers and may take fees that reduce recoveries. It advises customers to discuss any such approach with the liquidators first. It also warns of scams, including unexpected calls claiming to be from PPS Money, BTG Begbies Traynor, or the FCA.

For compliance teams, the priority is exposure assessment. Firms that use PPS Money for cross-border settlement, especially MSBs, should identify outstanding balances, in-flight payments, and unsettled obligations, and then file claims with the liquidators. Firms should also review payment flows and customer communications. Agents that were registered to provide services on behalf of PPS Money should confirm their status, stop acting for the firm where appropriate, and consider their obligations to their own customers. Teams should check whether any regulatory notification or reporting duties are triggered, and should document decisions and communications.

Beyond immediate response, the case highlights wider risks. Third-party and counterparty due diligence should specifically test whether a payment provider safeguards client funds, since small payment institutions are not required to. Firms should review concentration risk, settlement timing, and contingency or exit plans for payment providers. Customer-facing teams should be briefed to direct inquiries to the liquidators and to remind customers about scam risks. Fraud and financial crime teams should expect opportunistic scams and fee-charging recovery solicitations targeting affected customers. Because the PSRs do not require safeguarding for small payment institutions, the case may also draw regulatory and policy attention to that gap.

Source: Financial Conduct Authority