Legal Guidance and Research / Experts / Victoria McGowan
Victoria McGowan#13869

Victoria McGowan

Linklaters
Victoria is a Managing Associate in the Financial Regulation Group at Linklaters LLP. She is experienced in advising a broad range of clients, including banks, asset managers, prop trading firms and financial market infrastructures on advisory, contentious and transactional matters.

Victoria advises on a range of regulatory matters, including the regulatory perimeter, MiFID II/MiFIR, the UK and EU rules on sustainable finance, the UK and EU operational resilience and AI frameworks and the FCA’s Consumer Duty. 

In addition to her experience at Linklaters, Victoria spent a year working as a Judicial Assistant at the UK Supreme Court.  

Practice Area

Panel

  • Contributing Author

Experience

  • Linklaters LLP (2019 - 2025)
  • Supreme Court of the United Kingdom (2023 - 2024)

Qualifications

  • BA Jurisprudence (with Law Studies in Europe) (2017)
  • Bachelor of Civil Law (2018)
  • MSc in Law, Business and Management (2019)

Education

  • Pembroke College, University of Oxford (2013-2017)
  • Lincoln College, University of Oxford (2017-2018)
  • University of Law (2018-2019)

1 Contributions by Victoria McGowan

FCA Consumer Duty (UK) for Payments and e-money Firms: Scope, Distribution Chains, Cross-cutting Rules, Four Outcomes, and 2024-2025 Supervisory Findings
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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