Does a remittance service/app that help people to find hawaladars or others to exchange their money with, but does not take part in money transactions (exchange will be outside the service/app) need to be registered with the FCA or HMRC in the UK?

If you include a fee for registration and/or take a fee for enabling this transaction, then you would be required to register with the FCA / HMRC (IMHO) as you’ve just executed a function of an intermediary. There is a false sense that an intermediary has to have/channel the funds (i.e. touch the money) in […]

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