SCEL Statement and Commitment to Clients on its Consumer Duty


Smart Currency Exchange Limited “SCEL” is governed under the Financial Conduct Authority “FCA” Payment Service 2017 regulations as an authorised payments institution.

SCEL is committed to ensuring adherence to required consumer duty rules, based on SCEL’s business model and client relationship management processes. SCEL works on the basis of a non-advisory entity dealing in deliverable foreign exchange “FX” contracts. It is in this context that SCEL’s statements on its consumer duty are outlined below:

Charges and fees

End rip-off charges and fees

  • SCEL manages its margins based on the value that it is delivering and on the cost of currency, to ensure that there is no market abuse through excessive margin application in FX contracts.
  • Cancellation charges on FX contracts are calculated in accordance with fair valuation based on the prevailing exchange rate at the point of the FX contract cancellation.
Switch or cancel products

“Make it as easy to switch or cancel products as it was to take them out in the first place

SCEL offers to clients two main products for international payments. These two products are “Spot” or “Forward” contracts which SCEL offers under its terms and conditions signed up to by its clients. However, SCEL understands that circumstances can change during the contract period, and will endeavour to support its client in the following circumstances:

  1. Enabling a client to switch between a spot and forward contract where reasonable grounds to do so exist.
  2. Offer an extension on a forward contract if a client’s circumstances change, or if the client requires additional time to complete the contract. This extension may be subject to an adjustment in exchange rate in accordance with SCEL’s Terms and Conditions and as market conditions determine. This adjustment will be explained fully at that time and agreed with the client.
  3. Offer an early or staged settlement within the contract period where reasonable grounds to do so exist.
  4. Cancel a contract. (Note: Cancellation of a contract can lead to financial loss). SCEL will endeavour as far as possible to work with its client to find a solution where the client has fair and reasonable grounds on which to request cancellation of a contract or change terms of a contract.
Customer support

Provide helpful and accessible customer support, not making people wait so long for an answer that they give up

SCEL client services team is available to speak telephonically with clients during our operating hours of 08:30am to 6pm daily from Monday to Friday. Other channels available are email and post.

SCEL records client calls, which is a legal obligation. SCEL systems are set up to minimise the call waiting times of clients through use of effective screening and diversion tools as well as key performance measure within the teams.

Information provided

Provide timely and clear information that people can understand about products and services so consumers can make good financial decisions, rather than burying key information in lengthy terms and conditions that few have the time to read”.

SCEL Terms and conditions “T&Cs” are a critical element to SCEL and its client services team encourages all clients to read T&Cs thoroughly.

SCEL recognises the need to make things clearer. This is reflected in the way SCEL communicates its T&Cs and, when applicable, the internal review of customer complaints as outlined in the T&C’s.

SCEL issues all customers with its terms and conditions at account sign up. Clients attest to having read the T&Cs, which binds the client into a legal contract with SCEL when undertaking an FX contract. To encourage this, SCEL issues T&Cs to customers via several channels

  1. At account sign up stage online.
  2. Available as weblink on SCEL’s website 24/7.
  3. Post a hardcopy of T&Cs to all new customers as part of their welcome pack to their official address as provided to SCEL at account sign up.

SCEL maintains a booking process either through its online platform or telephonically, which is designed to provide the client with a very clear and plain summary of the foreign exchange contract the client is entering into.

Right products and services

Provide products and services that are right for their customers” –

SCEL offers its products on a non-advisory basis. However, SCEL spends time understanding its client’s requirements at various stages prior to entering into an FX contract and endeavours to make available the best possible solution from its product suite to satisfy the needs of its clients.

SCEL’s product range (spot/forward contracts) is designed to meet the needs of those requiring an execution-only service, that satisfies a specific deliverable need to fund a foreign currency payment on behalf of its clients.

SCEL does not allow speculative trading. SCEL always asks – and expects to understand – why the account is being opened and the reason for trade. SCEL is non-advisory and will provide detailed information about its products and services to help clients make an informed decision.

Protecting vulnerable customers

Focus on the real and diverse needs of their customers, including those in vulnerable circumstances, at every stage and in each interaction”.

While SCEL operates on a non-advisory basis with regards the products it offers, SCEL is committed to ensuring fair treatment of all customers including those considered to be vulnerable. You may refer to the SCEL Vulnerable Customers policy which outlines the approach and commitment.

SCEL also provides continuous internal training and quality control management programmes to re-enforce the importance and responsibilities of the “Treating customers fairly” and “Vulnerable client” process.

SCEL undertakes a number of measures at onboarding and throughout the client relationship, to understand the client’s circumstances and reason for trading. SCEL is able to offer fair value and high standard of service and support.

SCEL’s complaints process is available 24/7 on its website, with clear Service Level Agreements for response times which are aligned to the DISP 1.3 rules for FCA complaint handling.

SCEL understands how important it is to address client queries and concerns promptly and log them via its internal client relationship management system. Call recordings are available for adequate follow up.