Originally Posted by NALEM

So the Financial Conduct Authority in the UK publishes their decision on 26/06/2020 (June 26, 2020) that Wirecard can resume regulated activity,

and then ...

Paxum comes along on 29/06/2020 (June 29, 2020) to announce that "Paxum Takes Unprecedented Action to Return Clients Frozen Wirecard Card Funds Itself".

OMG. You make it look like you are going above and beyond, by advancing funds that are going to be released shortly anyways.

You may not owe it to your clients legally but you certainly owe it morally.
What you should of done, as soon as there was a whiff of troubles, is inform all your clients that they need to take certain precautions immediately (using alternative methods, withdraw funds, etc.) until this regulatory investigation is complete.