Our expertise

Our Managing Director, Payment Services, John Burns was member of the European Central Bank’s Forum on the Security of Retail Payments working on the requirements for Strong Customer Authentication and the Account Information Services and Payment Initiation Service. We have worked with payment service providers ranging from Small Payment Institutions up to Banks advising on the compliance with the requirements and, importantly, on the application of the exemptions under the Regulatory Technical Standards (RTS) to the business models of firms.

We are also experienced in assisting with applications for authorisation as a Payment Initiation Service Provider and/or registration as an Account Information Service Provider with the FCA (or Variations of Permission to add these activities to existing authorisations), including support through the FCA’s Sandbox.

It is a characteristic of the FinTech/Open Banking community that the business ideas developed were often “not in the contemplation of the legislators” when the regulations were drafted. We can provide detailed regulatory opinions identifying how the regulations apply (or do not apply) to innovative ideas, and indeed how business models can be structured to be within, or outwith, the FCA’s regulatory perimeter.

With the FCA’s increasing focus on the sector, it is important that firms have a good understanding of the requirements and how they can comply and prove that they are complying.

If you are already working in open banking and have a question, or are thinking about moving into the area, speak to one of the team. It could save you time and money in the long run.