Consumer Duty

Our Commitment

Consumer Duty is FCA’s regulatory framework designed to ensure that financial services firms prioritise the interests of consumers. The Consumer Duty sets the standard of care that we should provide to our corporate clients and their respective customers.

In all its activities, Clear Junction is committed to complying with the cross-cutting rules that define the expected standards of conduct by the FCA under Principle 12. The cross-cutting rules set out how Clear Junction, and all companies in the distribution chain, should act to deliver good outcomes for consumers. It requires Clear Junction, and all firms in the distribution chain, to:

Act in good faith towards retail consumers: Uphold ethical business practices and maintain transparency in our interactions with our corporate clients.
Avoid causing foreseeable harm to retail consumers: Proactively identify and mitigate risks that could negatively impact our corporate clients or their customers.
Enable and support retail consumers to pursue their financial objectives: Provide products, services, and support that empower our corporate clients to achieve their financial objectives while serving their customers responsibly.

Who We Are

Clear Junction is a group of companies which focuses on the wholesale market (financial institutions and regulated companies), where it uses its systems and payment infrastructure to offer access to interbank clearing through its own BIC, issuance of virtual accounts to facilitate payment reconciliation and other B2B services. Clear Junction works exclusively with corporate clients including remittance companies, banks, payment services providers, card issuers and digital currency businesses.

Clear Junction is committed to protecting individual consumers. Partnering exclusively with regulated companies and financial institutions helps ensure proper controls, support, and accountability for consumers financial well-being.

CLEAR JUNCTION NEVER PROVIDES SERVICES TO INDIVIDUAL CONSUMERS AND DOES NOT ESTABLISH BUSINESS RELATIONSHIPS WITH INDIVIDUALS.

We understand there may be instances of confusion among the customers of our corporate clients regarding the nature of our services. If you are an individual consumer seeking services from Clear Junction, please note:

We do not open accounts for individuals: If you need financial products or services, please contact financial institutions that provide services to retail customers (banks, or retail-focused payment companies). Make sure to verify that this financial institution opens accounts to individual consumers.

Contact your financial provider: If you have questions about your accounts, transactions, or other financial matters, please direct all inquiries to the financial institution you have a relationship with. If you have a fraud-related issue and you believe we can help you with it, please refer to our fraud prevention webpage.

In this policy below, when we refer to ‘clients,’ we mean companies that have a direct contractual relationship with Clear Junction. When we mention ‘customers,’ we are referring to the individual or business customers of our clients, who do not have a direct business relationship with us.

Payment Accounts

Collection Account

What is this product?

Collection Accounts are designed for regulated companies that offer various financial services like money remittance, crypto exchanges, other money services, and do not have bank, e-money institution or payment institution financial licences.

Here’s what a Collection Account allows these companies to do:

Collect customer payments: Companies can collect payments from their customers into a single account.
Non-individualised payment identifiers: Companies can create virtual accounts, linked to the main Collection Account, and assign these virtual accounts to their specific customers. This simplifies tracking and knowing exactly which payments belong to which customer. With virtual accounts, customers of companies can send and receive payments using the company’s name appearing on transactions (for example making a transaction to John Smith you will see ‘Company X’ as a recipient, not ‘John Smith’).

Key benefits include:

Companies can receive payments directly and seamlessly from their customers into the Collection Account.
Collection Accounts enable companies to accept payments from customers worldwide in a variety of currencies.
Collection Accounts can have additional services such as virtual accounts allocation to facilitate tracking and reconciliation of transactions, different payment methods, currency exchange, and other services to meet companies’ specific business needs.
Companies can have multiple Collection Accounts based on their needs and requirements.
Companies have the choice to manage their Collection Account through Clear Junction’s secure online portal or by API integration.

Clear Junction is satisfied that the design of the Collection Account product meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Collection Account target market is licensed financial institutions and regulated entities, payment service providers (PSPs), money transfer businesses, crypto asset businesses and other money service businesses.

Individuals cannot open Collection Accounts with Clear Junction, as they are exclusively designed for licensed financial institutions and regulated entities.

What are the limitations of this product?

The limitations of Collection Accounts will depend on the industry, licences, permissions, or specific regulations related to the Clients.

Companies using Collection Accounts are not able to assign virtual accounts in the name of their customers.

Collection Accounts must maintain a positive or nil balance at all times. Overdraft facilities are not available with Collection Accounts.

Correspondent Account

What is this product?

Correspondent Accounts are designed for licensed financial institutions like banks, payment institutions and e-money institutions, that are licensed to provide payment services to their customers.

Here’s what a Correspondent Account allows financial institutions to do:

Collect customer payments: Financial institutions can collect payments from their customers into a single account.
Individualised payment identifiers: Financial institutions can create virtual accounts, linked to the main Correspondent Account and assign these virtual accounts to specific customers. This simplifies tracking and knowing exactly which payments belong to which customer. With virtual accounts, customers can send and receive payments directly using their own names, rather than the financial institution’s name appearing on transactions (for example making a transaction to John Smith you will see ‘John Smith’ as a recipient, not ‘Company X’).

Key benefits include:

Financial institutions can receive payments directly and seamlessly from their customers into the Correspondent Account.
Correspondent Accounts enable financial institutions to accept payments from their customers worldwide in a variety of currencies.
Correspondent Accounts can have additional services such as virtual accounts allocation to facilitate tracking and reconciliation of transactions, different payment methods, currency exchange, and other services to meet their specific business needs.
Financial institutions can have multiple Correspondent Accounts based on their needs and requirements.
Financial institutions have the choice to manage their Correspondent Accounts through Clear Junction’s secure online portal or by API integration.

Clear Junction is satisfied that the design of the Correspondent Account product meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Correspondent Account target market is licensed financial institutions, including banks and electronic money institutions (EMI) and payment service providers (PSPs), that are duly licensed to provide payment services to their customers. .

Individuals cannot open Correspondent Accounts with Clear Junction, as they are exclusively designed for licensed financial institutions.

What are the limitations of this product?

Correspondent accounts must maintain a positive or nil balance at all times. Overdraft facilities are not available with Correspondent Accounts.

Corporate Account

What is this product?

Corporate Account is a separate business account designed to allow Clients to manage their essential daily business expenses, such as rent, salaries, and supplies.

Key benefits include:

Corporate Accounts can have multiple currencies therefore different payment solutions and currency exchange.
Clients have the choice to manage their Corporate Account through Clear Junction’s secure online portal or by API integration.

Clear Junction is satisfied that the design of the Corporate Account product meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Corporate Account target market is licensed financial institutions and regulated entities, including banks, payment service providers, money transfer businesses and crypto asset businesses.

Individuals cannot open Corporate Accounts with Clear Junction, as they are exclusively designed for licensed financial institutions and regulated entities.

What are the limitations of this product?

Corporate Accounts don’t support payments from Customers, only business-related payments are allowed for this type of account.

Corporate Accounts must maintain a positive or nil balance at all times. Overdraft facilities are not available with Corporate Accounts.

E-money Accounts

What is this product?

E-money Account is a specialised account for companies designed to handle incoming transactions of their corporate customers. It offers segregated e-wallets with unique IBANs, providing clear separation of funds and making reporting easier while meeting regulatory safeguarding requirements.

Key benefits for consumers include:

Each corporate customer gets a dedicated E-money Account with a unique IBAN, ensuring clear separation of funds. The funds are safeguarded in accordance with regulatory requirements.
Corporate customers’ E-money Accounts have individual balances.
E-money Account supports multi-currency capabilities, facilitating international transactions.

Clear Junction is satisfied that the design of the E-money Account product meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

E-Money Account target market is UK-registered companies that manage funds on behalf of their corporate customers. This usually includes:

Cashback and Loyalty Card Providers: Companies offering rewards programs with stored customer balances benefit from clear fund segregation and simplified reporting.

Online Marketplaces: E-commerce platforms, where buyers and sellers exchange goods and services, need efficient ways to manage transactions and protect customer funds.

Individuals can not open an E-money Account with Clear Junction, as they are exclusively designed for corporate clients and their corporate customers.

What are the limitations of this product?

E-money Accounts must maintain a positive or nil balance at all times. Overdraft facilities are not available with E-money Accounts.

In the online portal, clients can only manage their own E-Money Accounts and not their customers’ E-money Accounts.

Full integration via API is necessary to utilise the E-money Account to its full extent.

Escrow Accounts

What is this service?

Escrow Account is a service offered to cryptoasset firms, designed to safeguard transactions involving fiat currencies (EUR, GBP, USD) and cryptocurrencies. Clear Junction acts as an intermediary by holding fiat funds until all parties confirm the transaction has been successfully completed. Escrow Account can be opened only as an additional account to the Collection or Corporate Account.

Key benefits include:

Prevention of fraudulent or incomplete transactions by ensuring assets and payments are only released when all agreed-upon conditions are met.
Establishment of trust between buyers and sellers, particularly in large transactions or when dealing with unfamiliar parties.
Escrow Account can have multiple currencies.

Clear Junction is satisfied that the design of the Escrow Account service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Escrow Account target market is licensed or regulated cryptoasset businesses.

Individuals cannot open Escrow Accounts with Clear Junction, as they are exclusively designed for licensed or regulated cryptoasset businesses.

What are the limitations of this service?

To open an Escrow Account, the company must also maintain a Collection or Corporate Account with Clear Junction.

Limited to internal transfers between Client Accounts and supported blockchain transfers.

Transactions processed within standard business hours (8 AM – 5 PM UK Time).

Handles select cryptocurrencies (BTC, ETH, USDT, USDC) on compatible blockchains (BTC, ERC20, TRC20).

Escrow Accounts must maintain a positive or nil balance at all times. Overdraft facilities are not available with Escrow Accounts.

Virtual Accounts

What is this service?

Virtual account service is a unique reference number that is generated for a particular customer of a financial institution or regulated company making it easier to track and reconcile payments, especially when dealing with international transactions.

IMPORTANT: THIS IS NOT A PERSONAL OR BUSINESS ACCOUNT YOU OPEN DIRECTLY WITH CLEAR JUNCTION. It is a reference or routing number designed to assist financial institutions and regulated companies with matching payments to their source.

Virtual account service can be provided to financial institutions and regulated companies as an additional service to the Collection or Correspondent Account.

Key benefits include:

Virtual account service simplify payment reconciliation process and reduce the complexity of handling international payments.
Virtual accounts can be allocated in relation to individual or corporate customers of the financial institution.
Virtual accounts support payments in multiple currencies.
Virtual accounts can be allocated via Online Portal or API.

Clear Junction is satisfied that the design of the Virtual account service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Clear Junction offers Virtual account service to financial institutions, regulated companies, but not to individual consumers. Individuals cannot “open virtual accounts” with Clear Junction.

Virtual account target market is licensed financial institutions and regulated entities, including banks, payment service providers, money transfer businesses and cryptoasset businesses.

What are the limitations of this service?

The features and benefits of the virtual account service may vary based on the client’s license type and the payment services they are authorised to offer. Clear Junction tailors virtual account solutions to align with specific regulatory and operational requirements of our clients.

Payments

What is this service?

Clear Junction provides various payment routes for EU, UK, and global transactions, including:

SEPA CT and SEPA Inst EURO payments within the EU.
FPS, CHAPS, and incoming BACS Pound Sterling payments within the UK.
ACH, SWIFT, and Fedwire US Dollars payouts globally.
Internal payments within Clear Junction system.
Escrow Blockchain transfers.

Key benefits include:

Clear Junction’s global digital payment processing platform provides access to local and international payment rails, facilitating a wide range of transaction types.
SEPA Inst and FPS payment systems provide 24/7 payment processing.
Our fully automated solution enables Clients to submit payout instructions via our API or manually via our Online platform.

Clear Junction is satisfied that the design of the Payments services meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Payment services target market is licensed financial institutions and regulated entities, including banks, payment service providers (PSPs), money transfer businesses and cryptoasset businesses as well as UK-based marketplaces.

Clear Junction offers payment services to financial institutions, regulated companies and marketplaces, but not directly to individual consumers.

The evaluation and approval of payment systems offering is subject to Clear Junction’s risk appetite.

What are the limitations of this service?

SEPA Inst payment scheme has a payment limit of 100,000 EUR per payment. SEPA CT payment scheme operates exclusively on business days. Both SEPA CT and SEPA Inst are available only within the EU.
FPS scheme has a payment limit of 1,000,000 GBP per payment. CHAPS payment scheme is available only on business days. Incoming BACS payments are processed exclusively on business days. FPS, CHAPS and incoming BACS are available within the UK.
USD SWIFT and Fedwire payout volumes are limited and evaluated on a case-by-case basis.
Escrow Blockchain transfer is available only within Escrow Account service and in EUR, GBP and USD currencies.

Foreign Exchange (FX)

What is this service?

Foreign Exchange (FX) services are designed to facilitate seamless converting one currency (like pounds) into another (like euros or dollars). Our FX offerings include three primary execution methods to suit different business needs:

Instant FX: Provides real-time currency conversion based on live rates available through the CJ Online portal. This service is ideal for immediate transactions within business hours (06:00 am to 03:00 pm UK time).
Next business day (NBD): Tailored for large transactions exceeding 1,000,000, this service allows for currency conversion requests to be placed after regular working hours, with execution on the next business day.
Transactional FX: Designed to lock in FX rates for clients (providing a guaranteed FX rate), enabling them to price their goods and services in various currencies without the risk of adverse currency fluctuations. This service secures the exchange rate ahead of the transaction and executes the trade later, providing financial stability.

Key benefits include:

FX allows the conversion of one currency into another, facilitating international transactions and trade business activities.
Businesses can use FX to hedge against currency fluctuations, reducing the impact of exchange rate changes on their financial positions.
Effective FX management can help optimise costs by minimising the impact of unfavourable currency movements on financial transactions.

Clear Junction is satisfied that the design of the Foreign Exchange (FX) service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Foreign Exchange services target market is licensed financial institutions and regulated entities, including banks, payment service providers (PSPs), money transfer businesses and cryptoasset businesses as well as UK-based marketplaces.

Clear Junction offers FX services to financial institutions, regulated entities and UK-based marketplaces, but not to individual consumers.

What are the limitations of this service?

FX services are exclusively accessible to Clients with a multi-currency account in Clear Junction. The available currencies align with those present in the account.
FX operations are conducted during business days from 6 AM to 3 PM UK time.
Instant FX has a limit of 500 to 200,000 for a single conversion, with a maximum daily limit of 1,000,000.
Next business day FX has a minimum limit of 5,000 for a single conversion.
Foreign Exchange (FX) services are not available via the API and are available only via the Online portal.

Confirmation of Payee (CoP)

What is this service?

Confirmation of Payee (CoP) is an ‘account name checking service’ that can help avoid payments being misdirected due to errors providing a way to check the name on the account details of the person/entity they wish to pay. It provides customers (both personal and business) greater assurance that they are sending payments to the intended recipient, helping to avoid making accidental, misdirected payments to the wrong account holder, as well as providing another layer of protection in the fight against fraud and scams.

Clear Junction is a participant of CoP according to the Payment Systems Regulator Specific Direction 17.

Key benefits include:

CoP helps prevent misdirected payments by verifying that the payee’s name matches the account details.
CoP acts as a preventive measure against certain types of fraud, particularly those involving unauthorised or incorrect payments.
CoP aligns with regulatory requirements and industry standards, ensuring that financial institutions adhere to security and verification protocols.

Clear Junction is satisfied that the design of the Confirmation of Payee (CoP) service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Confirmation of Payee (CoP) service target market is licensed financial institutions and regulated entities, including banks, payment service providers (PSPs), money transfer businesses and cryptoasset businesses as well as UK-based marketplaces (to facilitate payments for themselves and their customers, using Clear Junction payment services).

Clear Junction offers Confirmation of Payee (CoP) solutions to financial institutions and marketplaces, but not directly to individual consumers.

What are the limitations of this service?

Clear Junction provides Confirmation of Payee (CoP) only to its direct clients.

Confirmation of Payee (CoP) is exclusively accessible for payment schemes for GBP transactions.

API

What is this service?

Our Application Programming Interface (API) is designed to allow Clients seamless connection to Clear Junction’s product offerings. The objective is to provide access to our real time payment processing services.

Key benefits include:

API integration allows different software systems to seamlessly connect and communicate with each other.
By automating the exchange of information between systems, API integration reduces the need for manual data entry and repetitive tasks.
APIs enable real-time data synchronisation between connected systems. This ensures that information is up-to-date across all integrated applications, providing users with accurate and timely data.

Clear Junction is satisfied that the design of the API service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

API service target market is licensed financial institutions and regulated entities, including banks, payment service providers (PSPs), money transfer businesses and cryptoasset businesses as well as UK-based marketplaces.

Clear Junction offers API solutions to financial institutions and marketplaces, but not to individual consumers.

What are the limitations of this service?

Foreign Exchange (FX) and CJClique services are not available via the API and are available only via Online portal.

Online Portal

What is this service?

The online portal is a secure web-based platform provided by Clear Junction. It serves as a centralised hub where Clients can access and manage their accounts and services 24/7. Through the online portal, financial institutions can perform tasks such as viewing account balances, initiating transactions, accessing reports, managing user permissions, and obtaining essential information related to their engagement with Clear Junction.

Key benefits include:

Clients can access the portal from anywhere with an internet connection, providing flexibility and convenience in managing their accounts and transactions.
The portal offers real-time updates on account balances, transaction statuses, and other relevant information, allowing Clients to make informed decisions promptly.
The portal provides access to comprehensive reports and analytics, empowering Clients to analyse their financial data.
The portal serves as a communication channel, allowing Clients to receive updates, notifications, and important messages from Clear Junction, fostering efficient and transparent communication.
A user-friendly interface enhances the overall user experience, making it easier for Clients to navigate the portal and perform tasks efficiently.

Clear Junction is satisfied that the design of the Online Portal service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

Online Portal service target market is licensed financial institutions and regulated entities, including banks, payment service providers (PSPs), money transfer businesses and cryptoasset businesses as well as UK-based marketplaces.

Clear Junction offers an Online portal to financial institutions and marketplaces, but not to individual consumers. Individual customers do not have access to the Online Portal, cannot interact with it and have no knowledge of its functionality or use.

What are the limitations of this service?

In order to register to the online portal, the user must complete ID and Facial verification. Certain functions or information may be restricted based on user roles and permissions (for example, if the user has read only access rights). Although the online portal is accessible 24/7, it may be unavailable during scheduled maintenance or unexpected outages.

CJClique

What is this service?

CJClique is a directory exclusively for Crypto businesses. It enables Clients who have agreed to be listed within the directory to contact each other to explore potential partnerships and streamline settlements by utilising our internal payments network.

Key benefits include:

Liquidity providers in the digital asset space hugely benefit from CJClique as they are able to easily identify crypto exchanges which are already part of this Client base.
Participation in CJClique opens doors to new opportunities, allowing Clear Junction clients to introduce their services to crypto businesses and forge valuable partnerships, thus driving business development and expansion.

Clear Junction is satisfied that the design of the CJClique service meets the requirements of the FCA Consumer Duty outcomes.

Who is the target market?

CJClique service target market is licenced or registered cryptoasset businesses upon their agreement to be included in the platform.

Clear Junction offers CJClique service to cryptoasset businesses, but not to individual consumers.

What are the limitations of this service?

CJClique is accessible to cryptoasset businesses that have opened a Collection Account with Clear Junction. Cryptoasset businesses have the autonomy to determine how much information they wish to share with other CJClique members.

CJClique services are not available via the API and are available only via the Online portal.