Additional instructions

Gemba is 100% legally responsible for the banking relationship. As the licensed provider, Gemba is the entity accountable to the FCA and to its correspondent banking partners for all regulated activities. The white-label agreement is a service contract that clearly stipulates that all regulatory obligations, reporting duties, and legal accountability remain with Gemba. This model is designed to provide partners with a "liability shield," allowing them to offer sophisticated financial products without undertaking the significant cost, complexity, and risk of becoming a regulated entity themselves.

Gemba assumes full financial liability for the reimbursement of client funds. In the highly unlikely event that a client's funds are lost or stolen due to a failure in Gemba's systems, processes, or a security breach of its infrastructure, Gemba is responsible for making the client whole. This responsibility is a fundamental component of the service and is contractually defined in the partnership agreement.

Gemba covers all legal costs, regulatory penalties, or fines that arise directly from the provision of the regulated payment services. A core part of Gemba's value proposition is to insulate its partners from the direct regulatory and legal risks inherent in operating a payment service. The partnership agreement includes indemnification clauses that protect the partner from liabilities stemming from a failure of Gemba's compliance or security systems. This contractual protection ensures that partners are not exposed to the financial consequences of regulatory actions or legal claims related to the underlying financial infrastructure.

Financial liability for breaches or fraudulent transactions that originate from failures within Gemba's infrastructure rests entirely with Gemba. This clear division of liability is essential for the white-label model. To further mitigate this risk, Gemba maintains a comprehensive professional indemnity insurance policy specifically designed for financial institutions, providing an additional layer of financial protection against such events. This is complemented by a robust security framework that has resulted in zero inbound or outbound fraud cases over the past 14 months.