Consumer Duty

In July 2023, the Financial Conduct Authority (the FCA) introduced ‘Consumer Duty’. It's a new legislation that sets higher and clearer standards of consumer protection across financial services in the United Kingdom. The Duty requires companies to put customer needs first and act to deliver good customer outcomes.


As an authorised and regulated payment institution overseen by the FCA in the UK, offering payment- and FX services to retail clients – private individuals, micro-enterprises, and small charities with an annual turnover of less than £1 million – iBanFirst fall in scope of Consumer Duty and are required to adhere to its principles.


We have taken the executive decision to extend the Consumer Duty principles to all our clients. Whether you’re a corporate or private client, retail or professional, we will ensure that you’re covered by the Duty. In doing so, our aim is to achieve positive outcomes for all our clients.


We’re committed to:

  • Actively pursuing favourable outcomes for all customers
  • Maintaining high standards in product and service quality
  • Ensuring pricing transparency
  • Promoting consumer understanding
  • Providing robust support


Our commitment to supporting vulnerable customers


A vulnerable customer is defined by the FCA as “an individual who, due to personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care”.


In layman’s terms, someone who’s classified as vulnerable is more at risk of not understanding the products or services they sign up for; making decisions that don’t generate a good outcome for them; or being unable to assess information given to them. While all companies should identify any signs of vulnerability and act appropriately, not all do.


At iBanFirst, we recognise this risk and thus have strict measures in place to identify signs of vulnerability and act accordingly. As human beings, we’re all at risk of becoming vulnerable at some point in our lives, whether short-term or long-term. 


Instances of vulnerability include, but are not limited to: 


  • Mental health struggles 
  • Job loss or change in jobs 
  • An unwell family member or friend 
  • Loss of a family member or friend 
  • Financial troubles 
  • Physical disability or impairment 
  • Ageing 


A vulnerable individual, whether a prospect or client, might not self-identify as vulnerable, and might not bring a change in circumstances to our attention. Hence, we train our staff to listen, identify needs, and adjust their approach accordingly, in case they recognise signs that a person they’re interacting with doesn’t have the capacity, at that moment in time, to make an informed decision about our products or services. Someone who’s considered vulnerable needs a different level of support compared to a prospect or client who isn’t.  


When we identify a vulnerability, we adapt out services to suit the needs of the individual and take extra precaution to ensure fair treatment in all our interactions and processes. We have also implemented an internal vulnerability policy and training programs for all our staff, to ensure a culture that prioritises understanding and addressing the risks of harm associated with vulnerability.

Prospects and clients alike can reach out to our team to discuss any concerns they have around vulnerability or adapting our services to their needs. Our team is available on +44 (0) 203 409 5400 or