The PAYTECH Book

How Payments Regulation and Compliance Can Create a Better Future

By Robert Courtneidge

CEO, Moorwand Ltd

Commencing my career as a young lawyer in Citibank Consumer Bank and Diners Club in 1990, I have lived the past 28 years as a payments lawyer navigating the ever-changing world of regulation and compliance. In the past year, as CEO of a regulated electronic money issuer with primary membership of Visa, Mastercard and UnionPay for issuing and acquiring and direct access to accounts at the Bank of England, Faster Payments and SWIFT pending, I can honestly say that the world today is so much more complex and challenging, but also more exciting and rewarding. In the past, regulation was led by the regulators who created a set of rules for the banks to follow and if you wanted to become part of the payments ecosystem, you either had to be a bank or work with a bank. This has changed significantly and the whole era of open banking¹ is here.

The first indication of change came in the early 1990s, when Tim Jones and Graham Higgins at National Westminster Bank conceived Mondex.² This was the first iteration of money stored on a chip on a card and was the forerunner of electronic money and electronic wallets as we know them today. It was in parallel with this that, in May 1994, the European Monetary Institute, now the European Central Bank, published its first report on “Prepaid Cards”.³ It looked at the advent of electronic wallets as developed initially in the prepaid phone vertical ...