Payments, including cross border payments, play a central role in international commerce. We have an experienced and capable payments legal and regulatory team that works with payment consulting, tax, financial crime and digital consulting colleagues to provide a comprehensive service.
The payments landscape is changing rapidly, with changes such as ISO 20022 migration, new payments architecture, open banking and CBDC among others. With focus turning to stablecoins and digital assets, inevitably the focus turns to fraud. In the UK, The Payment Systems Regulator (PSR) is introducing a mandatory reimbursement scheme for victims of authorised push payment (APP) fraud from 7 October 2024.
How KPMG can help
App scams:
- Liability management – advice on existing and proposed contractual arrangements, fraud prevention measures;
- Review of customer terms, consumer warnings (website, text message etc.), steps to create customer awareness
- Review of complaints handling and reporting policies;
- Staff training – customer facing and complaints handling (including recognising vulnerability);
- Compliance with consumer duty, data protection and other laws and regulations while implementing APP scam solutions
Review of Terms:
Review customer/ vendor terms and conditions to ensure compliance against data protection requirements, consumer duty, AML, PSD 2/3 and other regulatory requirements. Review of cash pooling structures, account terms, netting arrangements, other transaction documents.
Payment system design:
We can advise on the inception, and design of DLT based / innovative payment systems, geographical or feature expansion of existing payment systems. We can also structure new payments systems, products and services in local and international markets and with increasing regulatory scrutiny.
Tokenisation and digital assets:
We can assist with design and implementation of cross border payment solutions including tokenisation and digital asset solutions.
Regulatory health check:
Advising on PSRs, EMR, MiFID II and MiFIR, CASS, PSD 2 compliance. Advising on PSRs, EMR, MiFID II & MiFIR, CASS, PSD 2 compliance. FCA/PRA regulatory perimeter questions, de authorisation processes, hiving down strategy.
