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DAM(L’d) if you do, DAM(L’d) if you don’t – What should regulated firms be thinking about now the PoCA consent threshold has been...

On 10 July 2025, the UK raised the threshold below which certain regulated firms can perform acts that would otherwise constitute a money laundering offence. The new threshold is £3,000. This is the second rise in the...more

BNPL: Buy Now, Regulate in 2026 - FCA publishes proposals

Key takeaways The FCA has published details of the ‘proportionate’, ‘flexible’ and outcomes-focused conduct regime it is proposing for newly regulated BNPL agreements. These include a pragmatic approach to documentation and a...more

Buy-Now Pay-Later regulation: Government confirms final position

HM Treasury has confirmed its approach to the regulation of Buy-Now Pay-Later (BNPL) lending in its response to the October 2024 consultation. On 19 May 2025, Government also laid draft legislation before Parliament. Given...more

UK consumer credit act reform: Phase 1 consultation update

HM Treasury published its long-anticipated consultation on Phase 1 of the proposed reform of the Consumer Credit Act 1974 (CCA) on 19 May 2025. The consultation signals a significant move away from prescriptive legislation...more

UK consumer credit reform and buy-now pay-later regulation – May 2025 developments

On 19 May 2025, HM Treasury released a suite of publications as part of its ongoing efforts to modernise the UK’s consumer credit framework. These include the Consumer Credit Act Reform – Phase 1: May 2025 Consultation, the...more

Consumer Duty: UK FCA raises the bar for international payment pricing transparency

The FCA has published the findings from its review of firms’ approach to pricing transparency when offering UK customers international money remittance and cross border payments. It highlights proactive and clear disclosure...more

Good job, but keep going: UK FCA’s review of vulnerable customer treatment

During 2024, the Financial Conduct Authority (FCA) carried out a review of firms’ treatment of customers in vulnerable circumstances. After a lengthy and detailed review, the FCA published its findings on how firms support...more

The Payments Newsletter including Digital Assets and Blockchain, February 2025

Key developments of interest over the last month include: a new Bill containing detailed new information and account direct deduction obligations for banks and EMIs being introduced to the UK Parliament; the issuing of a...more

Comparative Guide: DLT and Innovations in Wholesale Settlement in Central Bank Money (UK)

In our previous Comparative Guide, we explored innovations in private forms of digital money and money-like instruments available to retail customers, including fiatreferencing stablecoins, e-money and tokenised deposits. As...more

The Payments Newsletter including Digital Assets and Blockchain, November 2024

Key developments of interest over the last month include: the UK Chancellor of the Exchequer makes her first Mansion House speech and HM Treasury publishes the National Payments Vision, indicating a focus on economic growth...more

UK Chancellor of the Exchequer’s Mansion House speech (14 November 2024) – summary of key initiatives

At her inaugural Mansion House speech on 14 November 2024, the Chancellor of the Exchequer outlined a number of key policy initiatives for the UK financial services sector. This note sets out the main initiatives, which...more

Buy-Now Pay-Later reform: UK government publishes updated proposals – now over to the FCA

HM Treasury has published its long-awaited response to the February 2023 consultation on its proposed approach to bringing Buy-Now Pay-Later (BNPL) within the FCA’s regulatory perimeter. The government is clear that “swift...more

UK Open Banking: PSR consultation response on Phase 1 expansion of Variable Recurring Payments

The Payment Systems Regulator (PSR) has published a response to its December 2023 consultation (call for views) which set out initial proposals on how the PSR could support the expansion of Variable Recurring Payments (VRPs)...more

UK Open Banking: PSR consultation on variable recurring payments and JROC update on progress

In the latest developments relating to the UK's open banking landscape, on 18 December 2023 the Payment Systems Regulator (PSR) released a consultation paper outlining plans for expanding variable recurring payments (VRP)...more

Hitting the brakes: UK FCA review of motor finance commission arrangements

Following a large number of complaints from motor finance customers in relation to discretionary commission arrangements entered into before the FCA's 2021 ban was introduced, the FCA has announced that it is using its powers...more

Borrowers in financial difficulty: FCA research report highlights areas of improvement for lenders

In the context of its ongoing Borrowers in Financial Difficulty project, the FCA has published a research report that suggests there’s scope for more and better engagement by lenders with such customers. The message in the...more

Buy-Now Pay-Later: HM Treasury sets out the government's approach to regulating the market

Hot on the heels of the government's commitment to reform the Consumer Credit Act 1974, HM Treasury has published the response to its October 2021 consultation on the scope and form of a new regulatory regime for Buy-Now...more

What’s mine is not yours. FinTech guide to relevant intellectual property and dispute avoidance (UK)

In the competitive world of FinTech, developing an effective Intellectual Property (IP) strategy early on is key. We have developed the Hogan Lovells IP FinTech Guide to assist you with key questions on this essential...more

Buy Now, Regulate Later: is a new regime on the horizon?

Following the Woolard review earlier this year, HMT has published its much anticipated consultation paper on regulating the Buy Now Pay Later (BNPL) market. The industry is likely to have mixed reactions to the proposals....more

New Release: Insurance Horizons Brochure 2021

The global pandemic brought a wave of changes and developments that have impacted, and continue to impact, the insurance sector. As we look ahead, we see further change on the horizon. Around the world, we continue to...more

UK open finance: FCA proposes industry-led phased approach

The FCA’s long-awaited feedback statement on open finance has been published. Findings from December 2019’s call for input suggest that, although there is a place for a regulatory framework to set outcomes, the best way...more

PSR publishes two calls for views on APP scams and consumer protection in interbank payments

The PSR is seeking views on potentially far ranging measures which aim to reduce authorised push payment (APP) fraud and improve protection for victims. Alongside this it is looking at increasing consumer protection in...more

Global Payments Newsletter, February 2021

Key developments of interest over the last month include: • United Kingdom: The Payment Systems Regulator (PSR) has published two calls for views, one of which focuses on authorised push payment (APP) scams and the other on...more

And so it begins: FCA consults on post-Brexit changes to SCA-RTS and Payments Approach Document

Barely a month since the end of the post-Brexit transition period, the FCA is consulting on changes to the onshored SCA-RTS and to the guidance in its Payment Services and E-Money Approach Document (and PERG). ...more

[Webinar] One year to go until the PSD2 RTS on SCA… are you on the right track? - September 20th, 12:00pm BST

With about one year to go until the European Banking Authority's Regulatory Technical Standards come into force, join us for a live webinar on 20 September to discuss the opportunities and challenges facing banks and...more

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