Gavin Punia
I am a regulatory specialist with a particular focus on advising firms who are digitally transforming the way financial services are being delivered.
I have developed a diverse range and in-depth experience of retail and wholesale financial services, including advising firms in the payments, brokerage, wealth management and crypto sectors. I offer particular experience in the regulation of payment services and electronic money products, crypto, investment services and insurance broking services.
I provide advice to payment service providers across the payment chain, including issuers, account operators, payment initiation providers, merchant acquirers and merchants, including e-commerce platforms.
The UK regulatory framework has constantly evolved over the last decade and the combination of advising clients on new financial services regulation with the development of new digital technology enables me to give practical and pragmatic advice. This ranges from organisational or governance requirements to advising on product specific issues across the development chain from regulatory perimeter issues, structuring the product and developing the contractual documentation.
My practice area also includes assisting firms with their compliance programmes for non-sector specific financial crime regimes such as anti-money laundering, bribery and corruption and market abuse, where I have advised a number of banks, lenders, investment firms, and insurers in recent years.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2011
Experience
- Norton Rose (2015 - 2017)
- DLA Piper (2009 - 2015)
Qualifications
- History (2007)
- GDL (2008)
- LPC (2009)
Education
- London School of Economics and Political Science (2004 - 2007)
- University of Law (2007 - 2009)
1 Contributions by Gavin Punia
PRACTICE NOTES
UK Authorised Push Payment (APP) Fraud Reimbursement Regime: FPS and CHAPS Rules, 50:50 Sharing, £85,000 Cap, Exceptions, Deadlines, and FCA/PSR/BoE Oversight
Introduction
On 7 October 2024, the Payment Systems Regulator (PSR) and the Bank of England unveiled a compulsory reimbursement regime for payment services providers (PSPs) when customers fall victim to Authorised Push Payment (APP) fraud. As the PSR describes it, APP fraud arises where a criminal deceives someone (often a consumer) into sending funds to an account they do not control. The principal scam types include:
‘malicious payee’—for example, a fraudster induces a person to pay for goods that do not exist or are never delivered;
‘malicious redirection’—for instance, a criminal impersonates a member of bank staff to persuade someone to move money from their bank account into the fraudster’s account.
In-scope payment firms
The APP fraud reimbursement duty applies to these categories of payment firms:
all payment firms participating in the Faster Payments Scheme (FPS) that provide relevant accounts; and
all payment firms participating in the Clearing House Automated Payment System (CHAPS) that provide relevant accounts.
These entities were expected to comply with the...
Financial Services
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