Clarified perimeter tests now capture embedded payments and wallet features once treated as ancillary. Expect supervisors to request reconciliations, safeguarding attestations, float governance, and merchant due diligence plans, plus evidence that customer funds segregation, settlement timing, and chargeback practices align with updated handbooks and notices.
Licensing increasingly hinges on transparent ownership, fit‑and‑proper attestations, and demonstrable control environments. Prepare for custody segregation proofs, token listing methodologies, market abuse surveillance coverage, Travel Rule readiness, and advertising workflows, each mapped to responsible officers, escalation paths, and independent testing schedules supervisors can verify quickly.
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