Payment systems are the infrastructure that underpins all services relating to the transfer of value. We are at the forefront of the legal developments in payment systems. As technological developments drive new business models, we have supported clients on many ground-breaking use cases within the sector, as well as the payments aspects of innovation in financial market infrastructure.

We have unparalleled experience in establishing global payment systems, both retail-facing and wholesale and in advising on the commercial arrangements. We advise on the inception and design of new DLT-based or other innovative payment systems and on the geographic expansion of existing systems. 

Our expertise spans drafting complex system rules, liaising with regulators and advising as to other commercial and structural arrangements, including outsourcing. We also regularly advise on issues of clearing, netting and settlement, including all aspects of settlement finality. Find out more about our wider Financial Market Infrastructure offering.

Case studies:

Fnality – new global wholesale payment system based on blockchain technology

Euroclear digital FMI for digital bonds

"Digital native and established financial institutions in payments alike, face intense regulatory scrutiny as they deploy innovative tech solutions in a complex and evolving regulatory environment"

Richard Hay
UK Head of Fintech

"We have advised on many of the most complex and cutting-edge matters in the market."

Michael Voisin
Capital Markets Partner, London

We provide clients across the payments sector with the right specialist teams to navigate the largest, most complex M&A deals. Our deep technical and commercial understanding of the sector and its infrastructure, our integrated cross-practice offering and the volume of payments deals we execute across our network set us apart. 

We also support our clients with a full range of corporate transactions and funding opportunities, including minority investments, funding rounds, corporate structuring, joint ventures and consortium arrangements, and entering new markets in a range of jurisdictions. We also work with clients to prepare for exits and liquidity events, including IPOs, disposals and selldowns. Across these transactions, our clients benefit from the expertise of our cross-border, cross-practice team both within the payments sector and across the full range of these corporate transactions. 

The payments sector also faces increased scrutiny from antitrust and foreign investment authorities, particularly due to the focus on companies that hold sensitive data, develop critical or emerging and innovative technologies (such as AI and cryptographic authentication), or are active in data infrastructure. We are well-versed in managing that dynamic on M&A transactions with the focus on helping client to get their deals done. 

We offer a one-stop shop for handling merger control and foreign investment review filings: a single, central point of contact and a coherent global strategy, critical to navigating merger control and foreign investment approvals successfully.

Case studies:

Wise listing

Bitpanda acquisition of a crypto custodian wallet provider

"The Fintech market is set for consolidation, particularly in payments, and that presents  a range of opportunities for clients that want to be part of this innovative, fast-paced sector”

Finn Griggs
Global Co-Head of Fintech, London

"Many fundamental growth drivers for the continued digitalisation of financial products, services and market infrastructure present investment opportunity”. 

Niranjan Arasaratnam 
Global Tech Sector Leader, Singapore

We undertake a broad range of work for our clients across the payments ecosystem including digital wallet providers, merchant acquirers, payment processors and providers of online payments gateways. 

We help them structure new products, including new forms of digital money/ stablecoins and CBDCs, and services in local and international markets and advise on insolvency risks in payments chains.

We advise on all facets of payments regulation, including new authorisations, structuring new products and services in local and international markets, and assisting businesses who find themselves under regulatory scrutiny. 

This may include obtaining authorisations, advising on regulatory capital and safeguarding issues, advising on and drafting documentation for payments propositions and advising on dealing with contentious, fraud and complaint cases, giving us a unique breadth and depth of expertise.

Case studies:

Crypto asset authorisation

UN High Commissioner for Refugees (UNHCR – The UN Refugee Agency) digital wallets

"Working is continuing on developing, and preparing the legal framework for, blockchain-based payments, whether in the form of stablecoins or central bank digital currencies - with hopes of solving the enduring instant payments and cross-border payments challenge."

Peiying Chua
Asia Head of Fintech, Singapore

"Payments services are of paramount importance not only for our financial services clients, but will equally be a key to success for many corporate and tech businesses – who need to be compliance focused as regulatory perimeter expands."

Andreas Van Impe
Financial Regulation Counsel, Brussels

Antitrust and foreign investment

Our deep experience advising on technological and regulatory change means we are well equipped to advise clients in the payments sector on the challenges associated with new payments technologies and products and increased regulatory focus on this area including antitrust and foreign investment in tech. 

Data and cyber

As cloud services, outsourcing arrangements and artificial intelligence solutions move to the centre of the value creation, so too do legal questions. 
We have extensive data protection experience and have advised numerous clients on how to best monetise their data – particularly relevant to the payments sector where huge volumes are produced and regulatory scrutiny is sharpening.

Cyber security is one of the most serious threats in payments and is increasing as payment infrastructures become more digitalized, integrated, and interdependent. Cyber risk management is a board level issue and we work with clients to build their cyber and operational resilience compliance – which is extending to all players in the payments ecosystem. They need to protect their intellectual property, and create the appropriate governance structures to respond quickly and appropriately to crisis events when they happen. 

Regulation of AI

The increasing adoption of AI in financial services generally continues to raise unique and complex ethical and legal challenges. A dynamic and evolving regulatory landscape, and increasing regulatory focus means firms will need to actively address the challenge of AI risk management. 
Our global, cross-practice team can advise on how to navigate the full spectrum of legal risks, as amplified by GenAI, arising from both internal operational and consumer-facing deployments. 

Employment & ESG

Clients turn to us to address their strategic employment and environmental, societal and governance (ESG) issues to best effect in areas such as workplace culture, diversity, pay and incentives, workforce restructuring, supply chain and climate change compliance and whistle-blowing. 

The Diversity Faculty – advising businesses on the legal, regulatory and governance aspects of diversity, equity, and inclusion

Our market-leading and multidisciplinary team of highly experienced equality and employment lawyers are at the forefront of advising clients on the legal, regulatory, governance, cultural and strategic diversity and inclusion aspects of their business. Explore the Faculty’s services here. 

"Maintaining customer trust in this fast-moving risk environment is a key priority for all payments providers"

Alex Roberts
China Tech Sector Leader, Shanghai

"A key challenge for payments businesses will be managing the evolving risk and compliance environment for GenAI”. 

Julian Cunningham-Day
Global Co-Head of Fintech, London

Given payments underpin the entire global economy it is an inherently complex area both in terms of the technology underlying the systems, services and products and the regulations governing them.

As a result, when disputes and investigations arise in the payments context, they are often serious and difficult. Clients need lawyers who understand the space and can advise in the light of the entire payments technological and regulatory landscape.

We work increasingly with clients in engaging with regulators across the globe, both to manage compliance risk and to support regulatory investigations when they occur and any resulting enforcement or litigation.

From advising on major regulatory investigations to urgent injunctions; from IP disputes to anti-money laundering investigations; from judicial reviews to sanctions issues – we’ve advised many of the world’s leading payments operators, and some of the most promising up and coming companies, on their most sensitive issues.

Case studies:

Payments related sanctions enforcement

Crypto asset authorisation

"Payments is experiencing continual disruption involving a constant flow of innovations and market entrants – leading to competitive tension and new risks. Expect to see the current regulatory focus on payment firms’ compliance with financial regulations continue – as well as disputes between those active in this space."

Ben Packer
Litigation, Arbitration and Investigations partner, London

"Regulatory focus continues on fintechs and payments firms inadvertently facilitating financial crime via money laundering, sanctions evasion or exposing their customers to fraud and scams.

Liz Dowd
Financial Regulation Partner, London