Legal
Service Description & Disclaimer
Last updated: August 2026
EXFI is the technology platform. Your account and your money are held by Gemba Finance Ltd, an FCA-regulated payment institution. Please read this document before opening an account.
In plain English
Who you're dealing with
Your account and your money are with Gemba Finance Ltd, an FCA-regulated payment institution (FRN 804853). EXFI is the technology platform you use to access it, operated by EX Financial Solutions Ltd.
Your money
Safeguarded by Gemba under UK payment regulations. Not FSCS-protected.
Problems with your account or money
Contact Gemba directly. Problems with the app or website: contact us.
1. About our services
EXFI is a financial technology platform operated by EX Financial Solutions Ltd, a company registered in England and Wales. EXFI is not a bank and EX Financial Solutions Ltd is not a bank.
All payment accounts, payment services, card services, and safeguarding of client funds are provided by Gemba Finance Ltd, a payment institution authorised and regulated by the UK Financial Conduct Authority (FRN: 804853). EX Financial Solutions Ltd acts solely as a technology and brand partner and does not itself hold, control, or safeguard client funds at any time.
Funds held in your account are safeguarded by Gemba Finance Ltd in accordance with the Payment Services Regulations 2017. Funds are not protected by the Financial Services Compensation Scheme (FSCS).
2.1 Nature of the Service
EXFI ("the Platform") is a branded technology interface operated by EX Financial Solutions Ltd ("EXFI Ltd", "we", "us"). The Platform provides access to payment services which are provided exclusively by Gemba Finance Ltd ("Gemba"), an authorised payment institution regulated by the Financial Conduct Authority in the United Kingdom (FRN: 804853).
EX Financial Solutions Ltd:
• is not a bank, credit institution, e-money institution, or authorised payment institution;
• does not accept deposits or issue electronic money;
• does not hold, receive, transmit, control, or safeguard client funds at any point;
• does not provide investment advice, credit, or any regulated financial service in its own right.
Your contractual relationship in respect of your payment account, the execution of payment transactions, the issuance and operation of any payment card, and the holding and safeguarding of your funds is with Gemba Finance Ltd, subject to Gemba's terms and conditions, which you accept when opening an account.
2.2 Custody and Protection of Funds
All client funds are received, held, and safeguarded by Gemba Finance Ltd in accordance with the safeguarding requirements of the Payment Services Regulations 2017. EX Financial Solutions Ltd has no access to, and exercises no control over, client funds, the accounts in which they are held, or the credit institutions at which they are placed.
Because Gemba Finance Ltd is a payment institution and not a bank, funds held in your account are not covered by the Financial Services Compensation Scheme (FSCS). In the event of Gemba's insolvency, safeguarded funds are required by law to be held separately from Gemba's own assets and returned to clients in priority to other creditors; however, no statutory compensation scheme guarantees repayment.
2.3 Limitation of Liability of EX Financial Solutions Ltd
To the fullest extent permitted by applicable law:
• EX Financial Solutions Ltd shall not be liable for any loss, damage, delay, or failure arising from or in connection with the provision, suspension, restriction, or termination of payment services by Gemba Finance Ltd, including but not limited to: the holding or safeguarding of funds; the execution, rejection, or delay of payment transactions; the freezing, blocking, or closure of accounts; card issuance or card transactions; foreign exchange execution; or any act, omission, insolvency, or regulatory action affecting Gemba Finance Ltd.
• EX Financial Solutions Ltd has no control over, and assumes no responsibility for, the business processes, operational decisions, compliance procedures, counterparty relationships, or financial condition of Gemba Finance Ltd.
• Any claim, dispute, or complaint relating to your account, your funds, or the execution of payment services must be directed to Gemba Finance Ltd in accordance with the complaints procedure set out in Section 2.4 below.
Nothing in this disclaimer excludes or limits any liability that cannot be excluded or limited under applicable law, including liability for fraud, fraudulent misrepresentation, or for death or personal injury caused by negligence, nor does it affect your statutory rights as a consumer or any rights you hold against Gemba Finance Ltd under the Payment Services Regulations 2017.
2.4 Complaints and Claims
Complaints or claims concerning your account, your funds, payment execution, or any regulated payment service must be submitted directly to Gemba Finance Ltd:
Gemba Finance Ltd
Level 39, One Canada Square
Canary Wharf, London, E14 5AB
United Kingdom
Complaints should be submitted in accordance with the complaints procedure set out in your account terms and conditions with Gemba Finance Ltd.
If you are an eligible complainant and are dissatisfied with Gemba's final response, you may be entitled to refer your complaint to the Financial Ombudsman Service (www.financial-ombudsman.org.uk).
Complaints relating solely to the EXFI website, app interface, or our technology services (and not to any payment service) may be directed to EX Financial Solutions Ltd at hello@exfi.co.
2.5 No Advice
Nothing on the Platform constitutes financial, investment, legal, or tax advice. Information is provided for general purposes only. You are responsible for assessing whether the services are appropriate for your circumstances.
2.6 Changes
Gemba Finance Ltd may amend its terms, fees, or service scope in accordance with its own terms and conditions. EX Financial Solutions Ltd is not responsible for such changes and will have no liability arising from them.