News & Analysis as of

Payment Systems Risk Management

Hogan Lovells

Payments and e-money: UK FCA emphasises importance of proportionate risk frameworks to firms’ sustainable growth

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The FCA has recently published the results of its multi-firm review of payments and e-money firms' risk management frameworks and wind-down plans. It once again highlights the need to develop frameworks and plans in-line with...more

Miller Nash LLP

Swipe, Tap, Comply: What PCI DSS 4.0.1 Means for your Business

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With the seemingly never-ending updates to B2B contracts for compliance with new (and amended) comprehensive state privacy laws, the U.S. Department of Justice’s bulk data transfer rule, and artificial intelligence (AI)...more

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

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On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more

A&O Shearman

PSR consults on the revocation of SD4

A&O Shearman on

The UK Payment Systems Regulator (PSR) has published consultation paper CP25/2 alongside a new webpage, proposing the revocation of Specific Direction 4 (SD4) and its amendment, SD4a. SD4, introduced following the PSR's 2016...more

A&O Shearman

FCA findings on risk and wind-down planning in payment and e-money firms

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The UK Financial Conduct Authority (FCA) has published the findings of its multi-firm review into risk management and wind-down planning across e-money and payment firms. While the FCA had observed examples of good practice...more

Troutman Pepper Locke

Federal Banking Agencies Issue RFI on Payments and Check Fraud Mitigation Strategies

Troutman Pepper Locke on

On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Senate Passes GENIUS Act

The recent advancement of the GENIUS Act marks a turning point in the regulatory treatment of stablecoins in the United States, establishing a federal framework for the issuance and supervision of payment stablecoins. The...more

Husch Blackwell LLP

False Claims Act Insights - How Payment Suspensions Can Impact FCA Litigation

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Host Jonathan Porter welcomes to the show Husch Blackwell partner Bryan Nowicki, a Madison-based member of the firm’s Healthcare group, to discuss payment suspensions involving the Centers for Medicare & Medicaid Services...more

Clark Hill PLC

Clark Hill 2025 Commercial Real Estate Outlook: The Number One Cybersecurity Threat Facing the Real Estate Sector

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When we talk to clients about cybersecurity, it tends to conjure up images of ransomware, systems that are encrypted and inaccessible, and stolen data. For the real estate sector, ransomware isn’t the largest cybersecurity...more

Sheppard Mullin Richter & Hampton LLP

Kansas City Federal Reserve Bank Explores Regulatory Risks in Gaming Ecosystems

On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more

McDermott Will & Emery

New PCI DSS 4.0 Credit Card Compliance Requirements Effective April 1, 2025

McDermott Will & Emery on

As of April 1, 2025, all merchants and third-party service providers (TPSPs) involved in processing credit or debit card payments must fully adhere to the enhanced security requirements outlined in the Payment Card Industry...more

American Conference Institute (ACI)

[Event] 9th Annual Legal, Regulatory and Compliance Forum on FinTech & Emerging Payment Systems - May 12th - 14th, New York, NY

Meet key stakeholders in Banking, FinTech, and broader payment systems next month at ACI’s 9th Annual Legal, Regulatory and Compliance Forum on FinTech & Emerging Payment Systems. Gain valuable insights from these industry...more

Morrison & Foerster LLP

All Your Sale Are Belong to Us - Mitigating IP and Payments Risk in In-Game Economies

As in-game economies evolve, the complexity surrounding virtual goods and services, content creation, and payment structures deepens. As part of this ongoing series on in-game economies, this installment explores issues...more

A&O Shearman

Financial Crime: The FCA’s Strategy for 2025 – 2030

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In its strategy for the next five years, financial crime remains a priority for the UK Financial Conduct Authority (FCA). While the FCA acknowledges the significant efforts firms invest in their anti-financial crime systems,...more

A&O Shearman

FSB forum on cross-border payments data

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The Financial Stability Board (FSB) has announced the establishment of a forum on cross-border payments data, a key outcome from the FSB's recommendations for data frameworks related to cross-border payments published in...more

A&O Shearman

UK Treasury policy paper on new approach to ensure regulators and regulation support growth

A&O Shearman on

HM Treasury has published a policy paper setting out the next steps to its approach on regulation and regulators. The three overarching actions are: (i) tackling complexity and the burden of regulation; (ii) reducing...more

Sheppard Mullin Richter & Hampton LLP

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

A&O Shearman

ECB flags reliance of EU card payments on international schemes

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The European Central Bank (ECB) has published a report on card schemes and processors. The report provides an updated analysis of the development of card schemes and processing entities in EU member states...more

Davis Wright Tremaine LLP

PCI SSC Clarifies Obligations for Ecommerce Merchants That Outsource Payment Card Processing

The Payment Card Industry Security Standards Council (PCI SSC) has issued an FAQ for ecommerce merchants that outsource their payment card processing to a vendor using an embedded payment page or form (such as an "iframe")....more

A&O Shearman

Wolfsberg Group FAQs to help assess risks generated by the emergence of digital assets for AML and CTF purposes

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The Wolfsberg Group has published FAQs on defining digital assets. The FAQs propose definitions to be used by financial institutions, policymakers, supervisors and regulators to understand the characteristics of digital...more

A&O Shearman

Wolfsberg Group guidance supplementing payment transparency standards

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The Wolfsberg Group has published guidance on payment transparency roles and responsibilities to supplement the Wolfsberg Group Payment Transparency Standards. The guidance discusses roles played by key actors in a payment...more

Clark Hill PLC

The Growing Cybersecurity Risks in the Cannabis Industry

Clark Hill PLC on

Those familiar with the industry know that cannabis retailers find themselves in a unique position compared to other product retailers. Cannabis retailers face significant regulatory hurdles to their operation—particularly in...more

Troutman Pepper Locke

Patriot Bank and OCC Sign Agreement to Strengthen Oversight and Payment Activities

Troutman Pepper Locke on

On January 14, Patriot Bank, N.A. entered into an agreement with the Office of the Comptroller of the Currency (OCC) to address and rectify several unsafe or unsound practices and violations of law. This agreement follows the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Pauses Supervision Order, Signals Potential Rescission

On February 8, the CFPB requested a 90 day stay in a lawsuit filed by a major tech company challenging the agency’s risk-based supervision order. The lawsuit, filed in the U.S. District Court for the District of Columbia,...more

A&O Shearman

UK Financial Conduct Authority Dear CEO letter on priorities for payments portfolio firms

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The Financial Conduct Authority has published a Dear CEO letter to firms in the payments portfolio sector (including payment institutions, e-money institutions and registered account information service providers). Although...more

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