We are investigating potential offences by Euro Exchange Securities UK Ltd (EES).
The reason for opening the investigation is that it appears to us that, between 1 February 2020 and 4 June 2026, EES may have committed offences under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs).
EES may have failed to take appropriate steps to identify and assess the risks of money laundering, including in relation to its customers, the countries or geographic areas where it operated, its services, its transactions and delivery channels, and sufficiently document and update that assessment.
It may also have failed to establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering identified in the risk assessment (as above), including in relation to:
- customer due diligence
- ongoing monitoring controls
- internal governance and oversight
- resourcing and allocation of responsibilities
- record-keeping and escalation/reporting mechanisms
We have not yet reached any conclusions in this investigation as to what has happened or as to whether EES has breached any relevant requirements.
More information
Our opening of this investigation is further to:
- Our announcement on 4 June 2026[1] confirming that we had required EES to cease carrying on any regulated electronic money or payment services and had successfully applied to the court for appointment of interim managers over EES due to the serious concerns around the way EES had operated its business indicating that there were significant risks of financial crime.
- Our further announcement on 11 June 2026[2] confirming the High Court appointment of special administrators, Duncan Perring and James Bennett of Teneo Financial Advisory Limited, under the Payment and Electronic Money Institution Insolvency Regulations 2021, who had taken control of the firm and had secured a significant amount of material and frozen funds.
- The First Supervisory Notice[3] (FSN) published on 2 August 2026. The FSN of 2 June 2026 confirmed that EES could not carry on electronic money services or payments services. It also placed an assets requirement on the firm requiring it amongst other things to not return, transfer, or deal in electronic money and ensure that all relevant funds are appropriately ringfenced in a designated safeguarding account.