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Rory Copeland

Biography

Rory advises financial institutions, payments providers and systems, e-commerce and tech platforms and central banks on a broad range of financial services regulatory matters.

His advice focusses on new product structuring and regulatory characterisation, regulatory compliance, and rules and legislation drafting, in the areas of payment services and systems, AML and financial crime, consumer finance, financial promotions and consumer protection, and foreign exchange.

Rory advises a range of crypto-exchanges, issuers and global financial institutions on the legal and regulatory treatment of their services and impacts of legislative changes. He has advised on the development of policy and legal frameworks for the regulation of virtual assets, the issuance of central bank digital currencies, participation in cross-border CBDC networks, and the tokenising of real-world assets. He provides technical expertise for structured finance and securitisation transactions involving cryptoassets.

Rory also provides specialist support in drafting and negotiating commercial contracts and on M&A for established and growth financial institutions. He regularly assists clients with ‘change in control’ submissions associated with acquisitions of regulated firms.

Rory’s academic writing and speaking has focussed on regulatory change in payment services, fintech and virtual assets, central bank digital currencies and emerging forms of payment fraud. He is the co-authority of an upcoming book chapter on central bank digital currencies (Oxford University Press, 2024).

Practice areas

  • Financial services advisory and regulatory
  • Payments and fintech
  • Bank regulation

Sectors

  • Banks
  • Financial institutions
  • Fintech
  • Technology

Selected experience

  • Numerous banks, electronic money institutions and payments institutions on all aspects of regulatory compliance for provision of a broad range of payment services, including safeguarding, strong customer authentication, customer T&Cs and emerging regimes like the Consumer Duty.
  • Numerous clients, including BigTechs, e-commerce platforms, a global banking group and a multi-currency corporate card issuer on their applications to become UK-authorised electronic money or payment institutions. This entailed drafting and review of the application documents, internal policies and the relevant Ts&Cs. We continue to provide ongoing regulatory support to these clients and have significant experience in engaging with the FCA.
  • A UK payment system operator on the structuring and drafting of a new Authorised Push Payment Fraud Reimbursement Scheme within its rulebook, as directed by the Payment Systems Regulator.
  • A global card scheme on the regulatory and contractual structuring and rulebook for a novel open-banking based payment arrangement, covering UK and EU payment systems and services, and consumer protection.
  • A UK payment system operator on the design and development of an account-to-account payments framework for Variable Recurring Payments and future use cases, in accordance with the directions of the Payment Systems Regulator.
  • Virgin Atlantic on the renegotiation of card acquiring arrangements with three card acquirers as part of Virgin’s solvent recapitalisation, and the negotiation and entry into three new acquiring agreements on novel data/reporting-driven terms.
  • Numerous ‘crypto-native’ and ‘traditional’ financial institutions on all aspects of the application of financial services, AML / financial crime, sanctions, data protection regulations to novel cryptoasset products and services, including global roll-outs, licensing projects, client documentation and regulatory engagement.
  • A global card scheme on the regulatory and contractual structuring of a global order-routing system for the purchasing and custody of interests in cryptoassets.
  • An investment firm on the structuring of an issuance of Luxembourg law governed bitcoin-linked ETF.
  • A G20 central bank on its strategy for virtual assets and a central bank digital currency, and drafting the necessary legislation to enable a licensing regime for virtual assets and the issuance of a CBDC.

Education

  • DipIPLS, Queens University Belfast, 2019
  • MA (Cantab), Cambridge University, 2021
  • BA (Cantab), Law, Cambridge University 2017

Admissions

  • Admitted as a solicitor (Northern Ireland) 2019
  • Admitted as a solicitor (England & Wales) 2021