Consumer Duty Implementation Statement

Introduction

Smartsend is fully committed to upholding the standards set by the Financial Conduct Authority (FCA) under the Consumer Duty. As a money service business, we recognize our responsibility to consistently deliver good outcomes to all retail customers who use our remittance, currency exchange, and payment services.
This statement outlines the key actions taken and the governance framework adopted by our business to meet the requirements of the Consumer Duty.

Our Commitment to the Consumer Principle

We operate in accordance with Principle 12: “A firm must act to deliver good outcomes for retail customers.” This is now central to our business model, customer service, and risk management framework.

Cross-Cutting Rules
  • Acting in Good Faith: All staff are trained to interact with customers respectfully, honestly, and with integrity.
  • Avoiding Foreseeable Harm: Our risk assessments proactively identify, mitigate, and monitor potential harm from our products and services.
  • Enabling Financial Objectives: Our communications and customer support channels are designed to help customers make informed choices that align with their financial needs.

Implementation of the Four Outcomes

A. Products and Services

  • We have conducted a full review of our services to ensure they meet the needs of identified target markets.
  • Clear documentation of our product approval and review processes is in place.

B. Price and Value

  • Each product has undergone a value assessment to ensure fees and charges are proportionate to the benefits delivered.
  • We benchmark pricing and review customer feedback and complaints relating to perceived value.

C. Consumer Understanding

  • Customer communications are tested for clarity and simplicity across all channels.
  • We have adopted plain English and visual aids, especially for explaining fees, timelines, and exchange rates.

D. Consumer Support

  • We have enhanced our support services and ensured priority services for vulnerable customers.
  • Response times, complaint handling, and service continuity are tracked via monthly KPIs and MI reporting.
Governance and Oversight
  • A Consumer Duty Champion has been appointed at Board level to ensure independent oversight.
  • Consumer Duty compliance is a standing agenda item at Risk and Compliance Committee meetings.
  • Annual board reports will review the effectiveness of our outcomes framework and identify areas for continuous improvement.

Culture and Staff Training
  • Staff performance objectives are aligned with customer outcome metrics.
  • Training programs embed the Duty’s principles and practical application in daily operations.

Looking Ahead

We are committed to continuous improvement and ongoing review of our customer outcomes framework. As market conditions and customer needs evolve, we will adapt our practices to maintain compliance and retain customer trust.

Signed
Compliance Team

Send money across borders with zero transaction fees.

#250 - 997 Seymour St. Vancouver, BC, Canada V6B 3M1

1001 S Main Street Kalispell MT 59901

124, City Road, London EC1V 2NX, United Kingdon

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“Smartsend Finance Limited incorporated in Canada is registered with FINTRAC in Canada as a Money Service Business (Registration Number: M23782550) and approved by the Bank of Canada as a Payment Service Provider (CASE-02581-V2S7X4)”

"Smartsend Finance Corporation incorporated in the United States of America is registered with the United States Treasury Department Financial Crime Network as a Money Service Business (Registration Number: 31000273618454)"

“SmartSend Limited is registered in the UK by the HMRC as a Money Service Business (Registration Number XNML00000201897)”

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