Where Are My Funds Stored?
This article explains where funds are held for Emburse Cards and how Stripe structures and safeguards those funds.
Stripe as the Funds Holder
Stripe is the processor of Emburse Cards and the party that holds funds.
How Stripe Holds Funds
Stripe holds user funds through regulated banking partners and accounts designed to safeguard customer funds.
Banking Partners and Account Locations
Stripe selects banking partners based on their ability to provide scale and stability for the services Stripe provides. Stripe predominantly holds user funds with FDIC-backed financial institutions such as Wells Fargo and Bank of America (for the U.S.), and Barclays, Citigroup, and Banking Circle (in the U.K. and EMEA).
Custodial Account Structure
Stripe holds user funds in pooled custodial accounts owned by Stripe’s licensed payments subsidiaries. Stripe holds user funds (including Emburse) in pooled custodial accounts owned by Stripe’s licensed payments subsidiaries: in the U.S., Stripe Payments Company (SPC); in the E.U., Stripe Technology Europe, Limited (STEL); and in the U.K., Stripe Payments UK Ltd. (SPUKL).
Account Titling for Customer Funds
Account titles indicate that the funds belong to Stripe’s customers and are not held for an individual named customer. For user funds, Stripe’s accounts are titled FBO, safeguarded, or client money to indicate that they are Stripe’s customer funds. These accounts are not titled for any individual named customer (including Emburse).
Ledger Tracking
Stripe tracks balances through internal ledgering. The balances of Emburse’s (and all other users’) funds are tracked via a Stripe ledger.
Protection of Funds and FDIC
Stripe structures its services and accounts to support segregation and identification of customer funds.
Separation in the Event of Insolvency
Stripe’s structure is designed to support identifying owed funds and disbursing them if needed. The services Stripe provides to Emburse are structured so that Emburse’s assets would be separated from Stripe’s bankruptcy estate in the very unlikely event of Stripe’s insolvency. Stripe’s ledgering supports prompt identification of who funds are owed to and subsequent disbursement of those funds.
U.S. FBO Account Titling
In the United States, Stripe uses segregated pooled deposit accounts titled to indicate funds are held for customers. In the United States and as described above, Stripe holds user funds in segregated, pooled deposit accounts that are titled and structured as FBO SPC Customers. The titling and structure of these FBO accounts indicate that the funds belong to the beneficiaries of the account (SPC users), not Stripe, and serve as an instruction to a bankruptcy court to set aside those funds from Stripe’s bankruptcy estate.
Non-U.S. Safeguarding Accounts
Outside the United States, Stripe uses safeguarding approaches aligned with local regulatory requirements. In non-U.S. jurisdictions, user funds are held either in similarly titled accounts or in safeguarded accounts in accordance with applicable local regulatory requirements. In EMEA, STEL and SPUKL hold local user funds in segregated safeguarding accounts established in accordance with safeguarding requirements under payments and e-money regulations. As per the applicable regulations, the funds in the safeguarding accounts will not form part of STEL or SPUKL’s assets until all user claims against STEL or SPUKL respectively have been discharged.