Victoria McGowan

Solicitor, 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.

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