Before Bank Payments can be enabled on your account, your organisation completes a Know Your Business (KYB) check. Huggg manages the process for you. This page explains what to expect and answers the questions organisations ask most.
🏦 Who are Token and Modulr, and why is Huggg asking questions on their behalf?
Token.io and Modulr are the two regulated partners Huggg works with to deliver Bank Payments. Both are authorised by the FCA (the Financial Conduct Authority, the UK's financial regulator).
Here is what each partner does:
Token.io is a Payment Initiation Service Provider, a firm licensed to start payments on an account holder's instruction. Token runs the KYB check, which is why their name is on the form.
Modulr FS Limited (FRN 900573) is an authorised Electronic Money Institution, a firm licensed to hold money as electronic money. Modulr opens and holds a regulated e-money account in your organisation's name.
The KYB questions on the form come from Token and Modulr. They are there to meet the partners' regulatory duties, not because Huggg has chosen to ask them. Huggg cannot change them.
You will not need to register with, log in to or contact either company. Your relationship stays with Huggg throughout.
You can check both partners on the FCA register at register.fca.org.uk.
📋 What does the onboarding process involve?
The onboarding process starts with a form and ends with Bank Payments enabled on your account. Huggg manages every step.
Here is how it works:
You receive a pre-filled application form from Huggg by email, built from the information you gave at sign-up.
You review, sign and return the form to support@huggg.me. DocuSign is accepted.
Huggg submits the form to Token, who run the compliance checks for both Token and Modulr.
Once both checks are complete, we enable Bank Payments on your account.
The process takes up to 7 working days. We will let you know as soon as you are approved.
💷 How does the Payments wallet work?
The Payments wallet holds the money you use for Bank Payments. Your main Huggg wallet covers all other voucher types, and the two are kept separate.
You top up the Payments wallet from inside the Huggg platform. Open the wallet and it shows you the account details to pay into.
Those account details are different from the ones for your main Huggg wallet.
Your top-up goes into the dedicated account Modulr holds in your organisation's name. The money is ring-fenced there, and the balance shows in your Payments wallet.
Two things follow from that split:
Both wallets sit inside the Huggg platform and you can see both at any time. There is no separate login or system to check.
Each wallet shows its own balance. The two are never combined or offset against each other.
You will always see exactly how much is held for Bank Payments and how much is held for everything else. Keeping the two apart is what keeps your Bank Payments money ring-fenced.
🪪 What information does the KYB form ask for, and why?
The KYB form asks for personal details about certain people connected to your organisation. Modulr opens and holds the regulated account, so the law says Modulr must verify who controls or is responsible for your organisation.
This is standard KYB compliance under the Money Laundering Regulations 2017. It is the same process a bank runs when opening a business account.
The details are used to run a 2+2 identity check. Two identifying details (name and date of birth) are checked against two independent data sources, such as credit reference or electoral roll records.
If the check cannot be completed from those details alone, Token may follow up to ask for photo ID and proof of address.
Huggg collects this information on Token and Modulr's behalf. You will not need to deal with either company.
What the form asks for depends on the type of organisation you are.
🏛️ What do councils need to provide?
Councils have a different governance structure to companies, and the form is built to match. A council application needs one signatory and three senior members of staff.
The signatory: name, date of birth and home address.
The signatory is the person your council authorises to sign and submit the form.
They do not need to be a senior post-holder. The lead of the relevant support scheme is fine, as long as they are authorised to sign.
The 2+2 identity check is carried out on the signatory only.
Three senior members of staff: name, date of birth and job title.
Modulr asks for three people who hold key financial oversight and decision-making responsibility.
These are the Chief Executive, the Chief Finance Officer (the Section 151 Officer) and the Legal Officer. Job titles vary between councils, so use the closest equivalent in yours.
No identity check is run on these three people.
For council onboarding, identity verification is completed on the signatory only. The three senior officers are named to evidence your governance structure.
📄 What do charities, NGOs and education providers need to provide?
Charities and similar organisations do not have a council's governance structure. Your form is built around one signatory, plus evidence of who ultimately controls the organisation.
The signatory: full name (including middle name), date of birth, home address and their position in the organisation. The form also asks whether they can act for the organisation on their own.
The 2+2 identity check is carried out on the signatory only.
If the signatory cannot act alone, Token also needs the names of the other required signatories.
Ultimate beneficial owners (UBOs): the names of anyone who controls how the organisation is run. Charities do not have shareholders in the way a company does, so this is how Token identifies who is accountable for decisions.
Regulatory and compliance questions: whether your activities need a licence, certification or approval, and confirmation that you hold them. The form also asks about any past legal sanctions or fines.
Supporting documents: send these to support@huggg.me. One email with a ZIP file is fine.
Charity Commission extract or register entry.
Governing document, such as a constitution, trust deed, memorandum and articles of association, or school funding agreement.
Anti-money laundering (AML) policy.
Your KYC and KYB onboarding process document. KYC (Know Your Customer) is the identity check on an individual. You only need to send this if it is not already covered in your AML policy.
As with councils, identity verification is completed on the signatory only. The UBO and document requirements evidence your organisation's structure and controls. No personal checks are run on anyone named there.
📊 Why does the form ask about expected transaction volumes and values?
The form asks for your expected monthly transaction volume and average transaction value so that Modulr can understand how you plan to use the account.
This helps Modulr meet its obligations under anti-money laundering regulations. A bank asks the same when opening a business account.
If you do not have exact figures, a reasonable estimate based on how you expect to use Bank Payments is fine.
🔐 Will personal details be shared with anyone outside this process?
Personal details are shared only with Token.io and Modulr. They are used only to complete the identity checks needed to set up Bank Payments on your account.
The legal basis is compliance with a legal obligation under the Money Laundering Regulations 2017.
If your data protection officer needs a full breakdown of what personal data is transferred, to whom, and under what legal basis, we can provide a data processing summary on request.
💳 Why is a financial account being opened for our organisation?
Modulr opens a dedicated e-money account for your organisation so that Huggg can legally process Bank Payments. An e-money account is a regulated account that holds electronic money.
It is not a replacement for your existing banking arrangements. It exists only to process the Bank Payments you send through the Huggg platform.
Your existing banking relationships are unaffected.
🔑 Do we need to open an account with Token or Modulr ourselves?
You do not need to open an account with Token or Modulr. You will never need to register with, log in to or deal directly with either company.
Both work entirely in the background. Your experience stays within the Huggg platform.
👛 Why can't our existing Huggg wallet be used?
Your existing Huggg wallet cannot be used because Bank Payments need a dedicated account, and that is a protection for your organisation. Regulations say your money must stay ring-fenced at every point.
It must never be pooled with other customers' money, and it must never pass through anyone else's accounts. That is why Modulr opens a dedicated e-money account in your organisation's name.
This makes no difference to how you work day to day. You use the Huggg platform exactly as you do now, and the dedicated account works behind the scenes.
❓ What if a senior officer is not comfortable providing personal details?
The identity requirement sits with Modulr as the regulated account provider. It is not a decision Huggg has made.
Any organisation opening an FCA-regulated account must complete this verification for the responsible people. That applies whether the account comes through a bank, a fintech or a platform like Huggg.
For councils and charities alike, the identity check runs on the signatory only. Everyone else named on the form gives their details to evidence your governance structure, and no check is run against them.
If a direct conversation with Token would help before you go ahead, we are happy to arrange that.
Still need help?
Email us at support@huggg.me and we'll do our best to assist.