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Kai Zhang

Kai Zhang is a special counsel and a member of the Payments, Banking Regulation, and Consumer Financial Services practice and a member of the Asset Management and Investment Funds practice.

His primary focus is the payment services and e-money regulation including PSD2 and EMD. Kai has extensive experience in advising on issues within the full spectrum of payments/e-money regimes ranging from authorisation, conduct of business requirements, open banking requirements, to operational compliance support. He also advises FinTech firms, payment gateway operators, technology providers, cryptocurrency businesses in relation to payment/e-money related matters, and other issues such as FSMA authorisation requirements.

In addition, Kai also focuses on the relevant requirements relating to asset management and investment funds, including AIFMD, MiFID II, and the Investment Firm Prudential Regime, with respect to issues such as cross-border AIF marketing, investment firm authorisation, client categorization, prudential requirements, and remuneration codes. 

He also advises on the general financial services regulatory framework such as financial promotion, FSMA licensing, change in control, as well as the anti-money laundering requirements.

Prior to joining the firm, Kai was an associate director at an international law firm. Kai focuses on financial services regulation. He focuses his practice on the payments and e-money regulatory frameworks including the Payment Services Directive, Wire Transfer Regulation and Electronic Money Directive. He has extensive experience in advising a variety of payment service firms (including banks, nonbank payment firms and FinTech firms) in respect of issues within the full spectrum of payments and e-money regulations such as authorisation, conduct of business requirements, the open banking regime and operational compliance issues as well as cryptocurrency-related matters. He also advises on the general regulatory frameworks such as the regulatory capital requirements for banks and investment firms, the anti-money laundering requirements for regulated firms, and the regulatory perimeter issues in relation with the Financial Services and Markets Act 2000 and the FCA Handbook.

  • Member of the Legal Task Force for Pay.UK (which is the UK retail payments authority responsible for the new UK domestic payment infrastructure).
  • “A Global Tour of Digital Assets Regulation - EMEA,” 10 November 2021, AIMA
  • Speech on PSD2 open banking at OpenBanking Expo (13 November 2019, London).
  • Panel speaker on PSD2 Open Banking requirements at Open Banking World Congress 2019
  • Speech on payments regulation at Commercial Payments International Europe Summit (6 March 2018, London).
Additional Thought Leadership Pages
  • PSD2 Open Banking: Allocation of Liabilities, The Fintech Times, Edition 32
  • PSD2 Open Banking - TPP Identification: To Check or Not To Check, Lexology
  • PSD2 Allocation of Liabilities: Customers v. ASPSPs v. PISPs, Lexology; Payments Cards & Mobile
  • AML and E-Money: FCA Thematic Review, Practical Law, 12 October 2018
  • Brexit – Potential Impact on the Payment and E-Money Sector, SA Financial Regulation Journal, 21 September 2018
  • The FCA: Level Playing Field or More Enforcement, Payments Cards & Mobile
  • Securitisation: Regulatory Framework and Reforms, co-author; Practical Law, July 2018
  • Payment Systems and Electronic Money Chapter in the Butterworths Financial Regulation Service (Loose-Leaf), Contributing editor, pre-2017
Additional News & Event Pages
  • Quoted in “Plus ça change for UK payment firms on Brexit Part 1 and 2, Vixio PaymentsCompliance, 24 and 25 November 2020
  • Quoted in “UK Regulator's Definition Of E-Money Firms As Trustees Sparks Debate,” Vixio PaymentsCompliance, 20 July 2020
  • Quoted in “Testing times: COVID-19 puts SME and APP fraud dispute resolution schemes under scrutiny,” Thomas Reuters – Regulatory Intelligence, 22 April 2020
  • Quoted in “Open banking impact may force regulators to reconsider prudential measures”, Global Risk Regulator (part of the Financial Times), 4 November 2019
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