HM Treasury’s Call for Evidence

Published on 22nd March 2023

We have submitted a response to the Call for Evidence issued by HM Treasury in connection with the review of the 2017 Payment Services Regulations.


It was submitted just before the collapse of Silicon Valley Bank and the unedifying spectacle of UK government ministers jumping up and down like marionettes to arrange a rescue of SVB UK, the ‘pocket bank’ to the UK’s fintech sector i.e. to Open Banking Third-Party providers, to eMoney Institutions and to Payment Institutions.

Our document was submitted before the voluminous letter sent by the Financial Conduct Authority on 16th March 2023 to the Chief Executives of nearly 300 such ‘fintechs’ which set out a laundry list of failings in the areas of protecting customers’ money and precluding financial crime.

We view the FCA’s letter as completely vindicating what we have written in our document on those two subjects, and in our Open Letter to the Payments Association about the scope of their Project Financial Crime, albeit that our letters was dismissed by The Payments Association as a ‘nothing to see here’, before the FCA issued its ‘Dear CEO’ letter.