Olivia Murphy

Managing Associate, Linklaters

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.

Contributed to

1

The FCA Consumer Duty – application to payments and e-money firms

Practice Notes

This Practice Note considers the implications of the Financial Conduct Authority’s (FCA) Consumer Duty for payments and electronic money (or e-money) firms. In particular, it considers the scoping exercise for payment and e-money firms, including relevant exclusions, the meaning of material influence, and the proportional application of the Duty. For those activities of a payments or e-money firm which fall within the scope of the Duty, it sets out a number of key considerations in respect of each cross-cutting obligation and each of the four retail customer outcomes.

Financial Services