Olivia Murphy
Olivia is a Managing Associate in the Financial Regulation Group at Linklaters.
Olivia has significant experience advising a number of fintech and payments clients on a wide range of issues ranging from authorisation, to conduct of business requirements and compliance with the UK anti-money laundering regime. Olivia has advised payments firms across the payments ecosystem including payment systems, acquirers and electronic money issuers. Olivia has also advised a number of clients in the cryptoassets space. Her deep knowledge of the payments ecosystem is built on her experience on secondment to a large payments system.
Olivia has also worked on a range of other types of regulatory matters including advising on perimeter issues, market abuse issues, regulatory authorisations, MiFID II and the UK client money rules.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2018
Qualifications
- University of Law (LPC) (2016)
- University of Law (GDL) (2014)
- University of Cambridge (B.A) (2014)
Education
- University of Law (LPC) (2016)
- University of Law (GDL) (2014)
- University of Cambridge (2011 - 2014)
1 Contributions by Olivia Murphy
PRACTICE NOTES
FCA Consumer Duty (UK) for Payments and e-money Firms: Scope, Distribution Chains, Cross-cutting Rules, Four Outcomes, and 2024-2025 Supervisory Findings
This Practice Note considers the implications of the Financial Conduct Authority’s (FCA) Consumer Duty for payments and electronic money (or e-money) firms
For the purposes of this Practice Note, a payments firm is used as a broad term for a ‘payment service provider’ (PSP) under the Payment Services Regulations 2017, SI 2017/752 (PSRs 2017).
Authorised payment institutions
Small payment institutions
Registered account information service providers
References to an e-money firm mean entities within the Electronic Money Regulations 2011, SI 2011/99 (EMRs 2011).
Authorised electronic money institutions
Small electronic money institutions
In broad terms, the Consumer Duty (the Duty) captures firms undertaking regulated activities in the UK that fall within the FCA’s scope. Some payment and e-money firms will deal directly with retail customers, while others participate indirectly through a distribution chain that reaches a retail end user. The Duty extends to both scenarios; however, the degree to which it bites depends on whether the firm sets, or has a material influence over, outcomes for retail customers. This Practice Note examines the scoping assessment for payment and e-money firms, including...
Financial Services
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