Numerous banks, electronic money institutions and payments institutions on all aspects of regulatory compliance for provision of a broad range of payment services, including safeguarding, strong customer authentication, customer T&Cs and emerging regimes like the Consumer Duty.
Numerous clients, including BigTechs, e-commerce platforms, a global banking group and a multi-currency corporate card issuer on their applications to become UK-authorised electronic money or payment institutions. This entailed drafting and review of the application documents, internal policies and the relevant Ts&Cs. We continue to provide ongoing regulatory support to these clients and have significant experience in engaging with the FCA.
A UK payment system operator on the structuring and drafting of a new Authorised Push Payment Fraud Reimbursement Scheme within its rulebook, as directed by the Payment Systems Regulator.
A global card scheme on the regulatory and contractual structuring and rulebook for a novel open-banking based payment arrangement, covering UK and EU payment systems and services, and consumer protection.
A UK payment system operator on the design and development of an account-to-account payments framework for Variable Recurring Payments and future use cases, in accordance with the directions of the Payment Systems Regulator.
Virgin Atlantic on the renegotiation of card acquiring arrangements with three card acquirers as part of Virgin’s solvent recapitalisation, and the negotiation and entry into three new acquiring agreements on novel data/reporting-driven terms.
Numerous ‘crypto-native’ and ‘traditional’ financial institutions on all aspects of the application of financial services, AML / financial crime, sanctions, data protection regulations to novel cryptoasset products and services, including global roll-outs, licensing projects, client documentation and regulatory engagement.
A global card scheme on the regulatory and contractual structuring of a global order-routing system for the purchasing and custody of interests in cryptoassets.
An investment firm on the structuring of an issuance of Luxembourg law governed bitcoin-linked ETF.
A G20 central bank on its strategy for virtual assets and a central bank digital currency, and drafting the necessary legislation to enable a licensing regime for virtual assets and the issuance of a CBDC.
A GCC central bank on the drafting of a virtual assets regulatory regime, including the review of payment systems laws for the use of DLT-based systems and the drafting ‘cryptoasset travel rule’ legislation. Rory on the drafting of payment services-focussed amendments to its payment services and stored-value facility regulations.
A GCC financial centre on the development of a real-world asset tokenisation regime, including amendments to laws governing the ownership and transfer of select asset classes and the drafting of a licensing framework.
