As a result of Farage's hissy fit over no longer meeting the commercial criteria for being a Coutts customer, the Tories clearly felt they had to do something. Well, here it is: 90 days' (instead of 2 months') notice to terminate a payment service contract that has no end date 'for convenience', with an obligation to explain and say how to complain. There are predictable exceptions, and this does not affect other grounds for contract termination or terminating/freezing an account/transaction. Yet more public funds have had to be wasted on a right wing conspiracy theory/culture war than solving an actual problem. Think Rwanda. Comments on this earth-shattering proposal are due by 14 April 2024 and the regulations might be laid before the General Election, or not... ;-)
As if they needed spelling out (as they would each render provision of the payment service unlawful in any event), the exceptions to having to give 90 days' notice of termination for convenience are stated to be:
- there's a requirement to cease activities under specific money laundering regulations;
- the related payment account turns out to be operated by a 'disqualified person' (under the Immigration Act);
- if the payment service provider reasonably believes a payment service provided under the contract is being/likely to be used in connection with a serious crime;
- if the FCA, Treasury or the Secretary of State lawfully require it; or
- if the payment service provider reasonably believes that the payment service user has committed an offence in connection with the user’s provision of goods or services to a third party.
A tale truly worthy of Macbeth's soliloquy.
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