Arjun Lakhani

Managing Associate, Linklaters

Arjun is a solicitor qualified in England and Wales and currently a Managing Associate in the Financial Regulation Group at Linklaters LLP.

He has a particular focus on, and significant experience in, the fintech and payments sectors. He has advised a variety of fintech companies, banks, payment systems and payment service providers on EU and UK law and regulation, including complex issues arising from, the recast Payment Services Directive, the Electronic Money Directive, anti-money laundering rules, and the Interchange Fee Regulation. Arjun has also counselled clients on the increasingly regulated cryptoasset and consumer finance (including buy-now pay-later) sectors. Furthermore,

Arjun has spent time on secondment at a designated payment system and an e-money institution.

Arjun has also worked on a variety of other types of regulatory matters, including advising on perimeter issues and regulatory change projects such as the recast Markets in Financial Instruments Directive, the Market Abuse Regulation, various Brexit projects and the FCA’s new Consumer Duty.

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