Regulatory Information

1. The Mando Group structure

Two layers operate in parallel to deliver Mando Network services:

• The technology layer (Mando Systems Ltd). This is the company you see — the brand, the apps, the dashboard, the mobile applications, the merchant tools, the wallet UI, customer support and marketing. Mando Systems Ltd is incorporated in England & Wales, Company No. 17168657, registered office 71-75 Shelton Street, Covent Garden, London WC2H 9JQ.
• The regulated payment layer (our authorised partner). A separate company, holding a Financial Conduct Authority authorisation as an Electronic Money Institution under the Electronic Money Regulations 2011 (the “EMRs 2011”). This partner processes card payments, issues Mando-branded debit cards, settles funds, holds customer balances in safeguarded client-money accounts, and is subject to the FCA Handbook (BCOBS, PRIN, SYSC, EMI sourcebook), the Payment Services Regulations 2017, the Money Laundering Regulations 2017, and the UK sanctions regime.

When you open a Mando account, you enter into two contracts — one with Mando Systems Ltd for the use of the software platform, and one with our regulated partner for the underlying payment, e-money and card services. The Mando Terms of Service incorporate the partner’s framework agreement by reference.

2. Where your money lives

Money loaded into a Mando Wallet is held as electronic money by our authorised partner in segregated UK client-money accounts at one or more major UK banks. Those accounts are safeguarded in line with regulation 21 of the EMRs 2011 — the partner cannot use customer money for its own purposes, customer money is ring-fenced from the partner’s general estate, and on insolvency customer claims rank ahead of general creditors over the safeguarded pool.

Customer balances are not deposits. They are not covered by the Financial Services Compensation Scheme’s deposit-protection guarantee (currently £85,000 per customer per bank). The protection is the safeguarding regime described above.

3. Who is responsible for what

Activity	Performed by	Regulated under
Marketing, brand, mobile and web apps	Mando Systems Ltd	UK consumer-protection law (CRA 2015, ASA codes)
Account opening, customer support, dispute triage	Mando Systems Ltd (operates partner’s flows)	Partner’s authorisation; UK GDPR, DPA 2018
Identity verification & KYC	Mando Systems Ltd + ID-verification vendors	MLR 2017, JMLSG guidance
Card payment processing	Authorised partner	EMRs 2011, PSRs 2017, FCA Handbook
Issuance of Mando-branded debit cards	Authorised partner (Visa / Mastercard licensee)	EMRs 2011, scheme rules
Holding & safeguarding customer balances	Authorised partner	EMRs 2011 reg. 21 (safeguarding)
Transaction monitoring & SAR filing	Authorised partner (Mando assists)	POCA 2002, MLR 2017
Sanctions screening	Authorised partner + Mando	UK sanctions regime, OFSI guidance
Software hosting, encryption, application security	Mando Systems Ltd	UK GDPR, DPA 2018, ICO codes

4. How to make a complaint

Most issues — app problems, account questions, support — are handled by Mando Systems Ltd directly. Email complaints@mando.network or write to the registered office above. Our internal target is to acknowledge within 1 business day and resolve within 15 business days.

Complaints relating to regulated payment services — refunds, chargebacks, unauthorised transactions, safeguarding — fall under the partner’s FCA authorisation. We will route those to the partner and reply within the statutory eight-week window required by the FCA dispute-resolution rules (DISP).

If we cannot resolve your complaint to your satisfaction within eight weeks, you may refer it free of charge to the Financial Ombudsman Service (financial-ombudsman.org.uk, 0800 023 4567). For data-protection complaints contact the Information Commissioner’s Office (ico.org.uk, 0303 123 1113).

5. Anti-money-laundering supervision

Mando Systems Ltd is supervised for AML purposes through the partner’s authorisation framework. Our internal AML programme — Customer Due Diligence, Enhanced Due Diligence for high-risk relationships, ongoing transaction monitoring, sanctions screening against the UK Office of Financial Sanctions Implementation list, and SAR escalation to the National Crime Agency — operates as part of the regulated chain. Our full AML policy sets out the controls.

6. What we are not

To avoid any confusion:

• Mando Systems Ltd is not a bank. We do not take deposits within the meaning of section 5 of the Banking Act 2009.
• Mando Systems Ltd is not directly authorised by the FCA. We do not appear on the FCA’s public register as a stand-alone authorised firm.
• Mando Systems Ltd is not a credit broker or lender. We do not extend credit to customers; any “buy-now-pay-later” option presented in checkout is provided by an authorised third-party.
• Mando Systems Ltd does not hold an FCA Firm Reference Number on its own account.

7. Information requests & supervisory contact

Regulators, law enforcement and other authorities seeking information about Mando customers should contact legal@mando.network. Where the request relates to regulated payment services we will route it to our authorised partner. Section 8 of the Privacy Policy describes the basis on which we share data with regulators.

Press, investor and partnership enquiries: hello@mando.network.