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E-money: operational solutions to blocked accounts in financing
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As discussed at length in our article, ‘Security over e-money and deposits with deposit aggregators: a new approach is required’ (2022) 10 JIBFL 682, e-money accounts have different features to traditional bank accounts and cash at bank. As such, the approach to taking security over e-money accounts must be different. This article considers one key difference – it is not possible to block e-money accounts as: (i) Electronic Money Institutions are under a statutory obligation to allow their customers to redeem their e-money at any time (regs 39 and 40 of the Electronic Money Regulations 2011 (EMRs)); and (ii) the balance must be capable of being used for payment transactions (reg 2 EMRs).
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