Safeguarding

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Passthrough Pay Inc. (trading as SWING) is registered as Money Services Business (“MSB”) with the Financial Transactions and Reports Analysis Centre (“FINTRAC”) (Reg. No.: C100000239)

Passthrough Company Limited (trading as SWING) is a company registered in Hong Kong, China. 

SWING’s payment and foreign currency exchange services are provided by Ebury Partners Hong Kong Limited, Ebury Partners Canada Limited and Ebury Partners UK Limited. SWING is partnered with Ebury Partners Hong Kong Limited, Ebury Partners Canada Limited and Ebury Partners UK Limited as a Programme Manager.

Ebury Partners Hong Kong Limited is regulated by the Customs and Excise Department as a Money Services Operator (MSO) to carry out remittance and money changing services. (License Number 18-09-02555).

Ebury Partners Canada is registered as Money Services Business (“MSB”) with the Financial Transactions and Reports Analysis Centre (“FINTRAC”) (Reg. No.: M17949017) and licensed as an MSB with the Authorité des Marchés Financiers (“AMF”) (Licence No. 904066)

Ebury Partners UK Limited is authorised andregulated by the Financial Conduct Authority as an Electronic Money Institution (Financial Services Register No. 900797). Ebury Partners UK Limited is registered with the information Commissioner’s Office, with registration number: ZA345828.

Capital Adequacy - The levels of capital requirements are based on Ebury’s level of activity. The FCA reviews Ebury’s capital adequacy on an annual basis.

Client Protection - Ebury’s client funds are held in segregated accounts, entirely separate from their own operating accounts, so client funds are always safeguarded.

Robust Internal Risk Management - Ebury has strict governance and operational processes in place to scrutinise the accuracy of each of their transactions, with appropriate involvement from their Directors. Compliance with Ebury’s governance and processes is regularly audited.