What is global payment network advisory for consumer credit firms?

It refers to advisory support to help consumer credit firms understand, comply with, and integrate within global payment networks like Visa, Mastercard, SWIFT etc., particularly when applying for FCA authorisation. This includes technical, regulatory, risk, and contractual aspects.

Why do consumer credit firms need to consider payment scheme rules when applying for FCA authorisation?

Because involvement in global payment networks adds additional regulatory, operational and scheme-compliance obligations. The FCA will want assurance that the firm meets these as part of its overall risk, governance, and compliance setup.

What technical or operational challenges are there for integrating with global payment networks?

Common challenges include message format compatibility, settlement flows, fraud prevention, ensuring real-time or near real-time processing, schema or network contract requirements, and ensuring secure, resilient infrastructure.

How does governance and internal control apply for payment network advisory?

Firms must ensure oversight of payment network relationships, ensure roles and responsibilities are clear, controls are in place for risk/fraud/dispute handling, contracts are reviewed, and compliance with scheme and regulatory rules is documented and monitored.

Is ongoing monitoring important after authorisation?

Yes. Payment schemes and regulations evolve, so continuous monitoring of changes, periodic reviews, updating of policies, and ensuring operations remain compliant are essential to maintain FCA authorisation and avoid penalties or operational risk.

FCA Authorization | Consumer Credit & Payments Advisory

Overview

This applies to firms facilitating cross-border payments, card processing, and working with payment schemes like SWIFT (Society for Worldwide Interbank Financial Telecommunication), Visa, Mastercard, etc.

Authorisation Process:

Business Model Structuring: Identify type (Payment Service Provider (PSP), Electronic Money Institution (EMI), or Money Service Business (MSB)), client base, settlement processes, and payment flow.
Scheme Compliance: Ensure operational and legal readiness to integrate with global payment schemes (e.g., Visa, Mastercard onboarding requirements).
Regulatory Classification: Determine whether firm falls under the Electronic Money Regulations 2011 (EMRs), Payment Services Regulations 2017 (PSRs), or Money Laundering Regulations 2017 (MLR 2017) for Anti-Money Laundering (AML) compliance.
Safeguarding Measures: Establish ring-fencing of client funds in designated safeguarding accounts.
Governance Framework: Compliance function, Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) policies, Ultimate Beneficial Owner (UBO) disclosures, IT security infrastructure.
FCA Application: Include technical architecture, compliance policies, and financial crime controls.
Ongoing Scheme Liaison: Aligning with scheme onboarding, chargeback mitigation, fraud controls, and compliance audits

Global Payment Network Advisory

Overview

Authorisation Process:

We cover the following areas under Global Payment Network Advisory: