Payment services

Recent Articles

  •  
    27.07.2021

    UK Government explores AML reform for Open Banking payment service providers

    The perceived disconnect between the compliance burden on account information service providers (AISPs), who provide “information only” services to customers to enable them to view consolidated financial information about multiple accounts, and the actual ML/TF risks their services are exposed to has been observed by market participants for some time. This had led to different approaches in practice as to the level of customer due diligence that AISPs carry out. The European Banking Authority (EBA) has also recently consulted on and issued updates to its Guidelines on ML/TF risk factors...
    Read more
  •  
    02.02.2021

    An Updated Approach: the FCA’s new Consultation Paper CP21/3 on Payment Services and E-Money

    This note summarises these changes and will be of interest to: credit institutions providing payment services and/or issuing e-money; payment institutions; e-money institutions; registered account information services providers; firms subject to the temporary permissions regime (the “TPRs”) and the financial services contracts regime; and Gibraltar firms providing payment services in the UK. 1. Amendments to the FCA approach document on payments and e-money The Approach Document sets out the regulators approach to the Payment Services Regulations 2017 (“PSRs”) and the...
    Read more
  •  
    17.07.2020

    FCA publishes Final Guidance and Dear CEO letter on Coronavirus and Safeguarding Customers' Funds

    The Guidance The Guidance aims to temporarily strengthen Payment Firms’ approach towards safeguarding and prudential risk management in light of Coronavirus and subsequent economic pressure. The FCA will conduct a full consultation later in 2020/21 on changes to its Approach Document. The key takeaways from the Guidance are as follows: Proposals for Payment Firms subject to safeguarding requirements Keeping records and accounts and making reconciliations – Where there is potential for discrepancies regarding the records and accounts of “relevant funds”, Payment Firms should...
    Read more
  •  
    02.07.2020

    FCA Research Note: Cryptoasset Consumer Research 2020

    On 30 June 2020, the FCA published a research note on cryptoasset consumers which forms part of the FCA’s work alongside the Government and the Bank of England (“BoE”) to understand market size, consumer profiles and attitudes towards cryptoassets[1]. The three institutions had previously, in October 2018, published a joint report as part of a UK Domestic Taskforce on Cryptoassets ( the “Taskforce”) which identified three major risks of harm associated with cryptoassets – risk to market integrity, financial crime risk and risks to consumers.
    Read more
  •  
    01.06.2020

    FCA proposed guidance for payment institutions and e-money institutions: Coronavirus and safeguarding customers’ funds

    The FCA states in the Consultation and in a related press release, that in line with the FCA’s 2020/2021 Business Plan, the payments sector is a priority area for the FCA and the Consultation is part of ongoing work to ensure that Payment Firms are adequately protecting customers’ funds. The FCA notes that although the sector is developing and growing rapidly, some Payment Firms are unprofitable in the early stages and many also rely on investor funds to remain solvent in the short-term. Some Payment Firms may also be facing decreased revenues because of coronavirus and it could be...
    Read more
  •  
    18.05.2020

    FCA accelerates digital sandbox pilot to support firms amidst the Covid 19 pandemic

    The FCA will be updating its webpage with information on the specific proposals, and welcomes both feedback on its proposals and expressions of interest from firms (regulated or unregulated) and stakeholders who are interested in participating or would like to contribute to the development of the digital sandbox. The digital sandbox – FCA’s plans The FCA is already a global leader in innovation, having set up the world’s first regulatory sandbox and being at the forefront of the Global Financial Innovation Network’s sandbox. Our article of February 2019 explores the FCA...
    Read more