I hope people found the webinar we at Cosegic did with Clear Junction last month useful and interesting. If you missed it, or would like to remind yourself of what was said,...
Recent banking app failures have raised the profile of operational resilience and its importance, but people may have missed the fact that in the run up to Christmas last year the FCA...
Keen followers of the political news will have seen that the Chancellor of the Exchequer recently held a meeting with the heads of UK regulatory bodies, urging them to remove barriers to...
Ambrose Bierce – The Devil’s Dictionary “Consult – To seek another’s approval of a course already decided upon.” Following the last minute decision of the Payment Systems Regulator (PSR) to consult (hurriedly)...
Payments, as I’m sure readers will have either read or heard me say before on numerous occasions, is the plumbing of financial services. Nobody pays it much attention when it is working...
“Nobody reads terms and conditions… do they?” We are all guilty of clicking on a button saying we have read and agree to terms and conditions online, without giving them even a...
Avid watchers of the FCA’s Twitter feed such as myself (and yes, I know how sad that makes me) may have spotted the regulator’s announcement on 31 May that Monneo Limited has...
Blackadder – “I’ve got a plan so cunning, you could put a tail on it and call it a weasel!” The similarities between Nikhil Rathi, Chief Executive of the FCA and Edmund...
On 13 January 2023, HM Treasury (HMT) published a Review and Call for Evidence on the Payment Services Regulations 2017 (PSRs). This document fulfills its statutory obligation to review the PSRs and...
The FCA’s focus on customer protection and service, as evidenced by the new Consumer Duty, is being reinforced by their actions across the regulatory piece. This can be seen in the regulator’s...
Fraudsters are very good. Very good at convincing ordinary people to send them money, by thinking that they are protecting themselves, or paying a valid invoice. You can tell this from UK...
Dedicated readers (there must be some?!), may recall my article on the implications of the Appeal Court judgment in the Ipagoo case which the FCA lost, where I said that, in that...
The indie rock bank Arcade Fire have a song on their “Neon Bible” album titled “Intervention”. The song begins with crashing chords on a church organ, building up an ominous sense of...
As one of the aims of The Payment Services Directive (PSD), (from the very first European Commission proposal for “A New Legal Framework for Payment Services in the Internal Market”), was always...
Listeners to Radio 4’s venerable “I’m Sorry I Haven’t a Clue” will know the ”Uxbridge English Dictionary” round, where panelists provide new definitions for common words. Among my favourites (well, those that...
Even in post-Brexit UK, the Payment Services Directive (PSD) continues to throw its long shadow over everything related to payments, so the EU’s plans for and discussions about the content of the...
Any experienced Compliance Officer or MLRO (Money Laundering Reporting Officer) reading the EBA’s Final Report and Guidelines on the Role of the AML/CFT Compliance Officer is likely to be struck by how...
Avid watchers of FCA court cases may have noticed that on 9 March the FCA lost its appeal against the decision of the High Court in the case of Ipagoo LLP that...
My old maths teacher at school used to say, “If you assume, it makes an ass out of u and me”. Reading the FCA’s Thematic Review TR 22/1 on wind-down planning, along...
The above misquote from my illustrious ancestor, Robert Burns (the actual line from his poem “To a Mouse” is “the best laid schemes o’ mice and men, gang aft agley”) came to...
The announcement from the Open Banking Implementation Entity that the number of users of open banking services in the UK has passed the 5 million mark means that open banking is a...
As I have mentioned in my article of 8 July last year (What is a Consumer?), whenever FCA guidance refers to dealing with consumers, it is always a good idea to check...
At the end of April last year, we held a Webinar on the New Operational Resilience requirements which the FCA is introducing Payment Services: Building Operational Resilience and which apply to all payment...
According to its website, the FCA levied fines totaling £567,765,219.95 in 2021. This is a huge increase from the £192 million levied in 2020. This includes the huge £264,772,619.95 fine imposed on...
In its Business Plan 2021/22 in July 2021, the Financial Conduct Authority (FCA), reminded us of its intention to remove firms’ permissions that aren’t being used. In line with Nikhil Rathi’s priorities...
Payment Institutions and EMIs who are clients of Cosegic will have heard James Borley and myself say many times over the past couple of years that, while the Senior Managers & Certification...
In July of this year, The Competition & Markets Authority (CMA) wrote a letter to the Open Banking Implementation Executive, which marked a significant step forward for the Payments industry by facilitating transfers...
The COVID pandemic, and subsequent lockdowns, has meant that many firms have been forced to reassess their way of working, with employees working from home all or part of the time becoming...
In the blizzard of tweets, e-mails and other output emitting from the Financial Conduct Authorirty (FCA), it may seem that the publication this morning of the FCA’s Business Plan for 2021/22 is...
As readers will be painfully aware, the Financial Conduct Authorities (FCA’s) focus on payment services and E-money is becoming ever greater. This is in huge contrast to the previous reactive approach and...
The Financial Conduct Authority’s (FCA’s) operational objectives specifically include securing an appropriate degree of protection for consumers, and promoting effective competition in the interests of consumers. The FCA’s 2020-21 Business Plan mentions...
Payment Services and E-money Institutions will be aware that they have (in theory) had the option to safeguard using the bank guarantee method since the implementation of the first Payment Services Directive (PSD1)....
The Financial Conduct Authority (FCA) has announced another six month extension to the deadline for implementing Strong Customer Authentication (SCA) for card-based e-commerce transactions. The new deadline is now 14 March 2022....
Those who joined our ‘Payment Services: Building Operational Resilience‘ webinar on 29 April 2021 will have an understanding of the work that Payment and E-money Institutions will have to carry out to...
On 31 March 2021, the Financial Conduct Authority (FCA) published PS21/4, extending the scope of firms required to submit an annual financial crime report. Firms that already submit this return will know...
Authorised Payment Institutions (APIs) and E-money Institutions (EMIs) are required to safeguard ‘relevant funds’ by virtue of the Payments Services Regulations 2017 (PSRs) or the E-Money Regulations 2011 (EMRs). Many foreign exchange (FX)...
Payment Institutions and E-Money Institutions struggling to find a safeguarding account in the UK may be unaware of a potential new opportunity as a result of Brexit. But those firms looking to...
Authorised Payment Institutions (APIs) and E-Money Institutions (EMIs) could be forgiven for not paying attention to the launch of a new consultation last month. But they might be well advised to take...
The Financial Conduct Authority (FCA) announced on 9 July 2020 that they require all E-Money Institutions, and any Payments Institution that is required to arrange an audit of its annual accounts under...
On the 9 July 2020 the Financial Conduct Authority (FCA ) published additional guidance for payment and e-money institutions. This followed a consultation that involved more than 60 organisations including payment firms,...
On 22 May 2020, the Financial Conduct Authority (FCA) issued a consultation proposing additional temporary guidance to strengthen payment firms’ prudential risk management and arrangements for safeguarding customers’ funds, in view of...
Payment Service Providers (PSPs) with permission to provide payment accounts may have or be about to receive a communication from the Financial Conduct Authority (FCA). This requests information about the payment accounts...
Each year in April the Financial Conduct Authority (FCA) publishes its annual business plan and it usually garners much interest. This year it seems to have gone below the radar as firms...
In the context of the Covid-19 (Coronavirus) outbreak, financial services regulators have been working with firms to ensure they are responding effectively to the threat of disruption. All firms are expected to...
View a recording of this webinar below Regulation 100 of the Payment Services Regulations 2017 comes into effect on 14 September 2019, requiring all Payment Service Providers operating remotely to issue payment...