9. Safeguards

9-1	As defined by the Central Bank, the fundamental safeguards to mitigate the inherent risks in innovative financial technologies focus on two key areas: Consumer protection and protection of the financial system.
9-2	The Participant shall have the following minimum safeguards in place:
		(a)	adequate Consumer complaint(s), compensation and dispute resolution mechanisms communicated to the participating Consumer(s);
		(b)	Consumers’ funds and / or assets shall be segregated from the Participant’s funds and entrusted to banks licensed by the Central Bank through an escrow account arrangement;
		(c)	adequate data handling, management and protection mechanism;
		(d)	restrictions on the Consumers that may be served, including the obtaining of express and informed, written Consumer consent as described in 7.1(b)(vii) for any Consumers that are served;
		(e)	ensuring the on-going fitness and propriety of any individuals connected to the Participant identified in 7.1(b)(vi) and
		(f)	necessary measures to prevent money laundering and to counter the financing of terrorism in accordance with all applicable anti-money laundering and counter-terrorist financing legislation and regulations.
9-3	The Central Bank shall review the Participant’s ongoing compliance with these safeguards and any other safeguards it requests of the Participant, both on an ad hoc basis and as part of the reporting obligations agreed with the Participant in 12.