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Kai Zhang

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

His primary focus is the regulation of asset management and investment firms, including AIFMD, UCITS and MiFID II as well as the related financial services regulatory frameworks such as regulated activities, financial promotion, TCFD disclosures and the Consumer Duty. The matters he advises on include investment funds distribution, asset manager prudential requirements, FSMA licensing, changes in control and conduct of business requirements such as client categorization and remuneration codes.

He also advises regularly on the regulatory requirements for payment service providers and e-money issuers and other fintech firms including crypto asset businesses, such as the Payment Services Regulations, the Electronic Money Regulations, the Interchange Fee Regulation, the crypto financial promotion rules and other issues within the full spectrum of payments and e-money regimes including FCA authorisation, open banking requirements and operational compliance support. His clients in these areas include large banks, authorised payment firms, payment gateway operators, technology providers and card programme operators.

Prior to joining the firm, Kai was an associate director at an international law firm and prior to that a senior associate at another internal law firm.

  • Recognised by The Legal 500 United Kingdom as a Recommended Lawyer for Financial services: non-contentious/regulatory and Retail funds, 2025
  • Member of the AIMA Digital Assets Working Group
  • Judge on the Pay360 Award programme held by the Payments Association
  • Panel speaker at AIMA "Digital Assets Regulatory Outlook Series – EMEA", 25 June 2024
  • Panel speaker at AIMA "digital assets live - London" event, 8 October 2023
  • Panel speaker at AIMA “A Global Tour of Digital Assets Regulation - EMEA”, 10 November 2021
  • Speech on PSD2 open banking at OpenBanking Expo, 13 November 2019
  • Panel speaker on PSD2 Open Banking requirements at Open Banking World Congress 2019
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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