Following my well-received blog about the ACPR’s approach to UK payment/e-money institutions applying for authorisation in France as part of their Brexit strategy, it was almost obvious that I should follow this up with consideration of near-neighbours Belgium.
For some, Brexit may still seem like something out of a fairy tale but, whether you are for or against, it will become a reality next March 2019.
The third in my trilogy of PSD2 blogs from ‘Inside the Regulator’. However, as we are now entering uncertain and uncharted territory, in terms of firms that failed to submit applications for re-authorisation in time, my insights are more presumptive than previously.
Drawing on my experience of heading up the Payment Services Authorisations Team at the FCA for many years, I spoke last week (http://blog.fscom.co.uk/psd2-a-glimpse-inside-the-regulator) about the FCA’s expectations for authorisations and re-authorisations, and offered some insight into how they might approach the challenges brought about by PSD2. I now explore the risks inherent in firms wishing to ‘upgrade’ their licences, the new entrants under PSD2 and the FCA’s approach to supervision.
Much of our time is, and seems always to have been, spent trying to interpret exactly what the regulations or, more importantly, the Regulator is expecting. A leading question asked by many compliance officers is, 'what do they expect of my company?'. This is often where the compliance consultant comes in.
‘Compliance’ is the watchword in financial services, perhaps more now than ever. With new rules and regulations being introduced across Europe, most notably 4MLD, MiFID II, PSD2 and GDPR, Heads of Compliance across multiple industry verticals are now under major pressure to ensure their processes and procedures are up to date, adequate and compliant.