Advisory and product structuring

We provide advice to fintech and financial services businesses on the structuring, development and operation of payment, e-money and cryptoasset products and services.

A core part of our work is helping clients understand whether their activities fall within the regulatory perimeter and, where they do, what permissions and compliance requirements apply.

Regulatory perimeter advice

We advise clients on the scope of regulation under the Financial Services and Markets Act 2000 (FSMA), the Payment Services Regulations and the Electronic Money Regulations.

This includes assessing whether a proposed product or service constitutes a regulated activity, and advising on the regulatory permissions that may be required to operate in the UK

Structuring products and services

We support clients in structuring business models in a way that is commercially effective and aligned with regulatory requirements.

This may involve advising on how a product can be delivered within an authorised model, or alternatively how it may be structured to fall outside the scope of regulation where appropriate, including through the use of available exclusions and safe harbour.

Exclusions and safe harbours

We have dedicated expertise advising on the negative scope of regulation, including exclusions under the payments and e-money frameworks such as the Limited Network Exclusion, the Electronic Communications Exclusion and the Technical Service Provider Exclusion.

We assist clients in understanding how these provisions apply in practice and in documenting regulatory positions where needed.

Commercial documentation

We also support clients by drafting and negotiating the commercial agreements that underpin regulated services, including outsourcing arrangements, intra-group service models and customer-facing payment frameworks, ensuring alignment with applicable conduct of business requirements.