Arjun Lakhani

ARJUN LAKHANI is a payments and fintech regulatory adviser with extensive experience advising banks, payment systems, fintech companies, and other financial institutions on UK and EU financial services regulations. While his practice spans the full range of financial services regulatory issues, Arjun has a particular focus on payments, e-money, and fintech, including complex matters arising under the Payment Services Directive (PSD2), the E-Money Directive, anti-money laundering (AML) rules, and the Interchange Fee Regulation (IFR).

Arjun advises clients on a wide variety of regulatory and compliance issues, including authorizations and regulatory structuring, safeguarding and other conduct of business requirements, outsourcing and operational resilience, and regulatory engagement with supervisory authorities such as the FCA, the Bank of England, and the Payment Systems Regulator. He has also supported numerous UK and EU regulatory change and implementation projects, helping clients adapt to major reforms such as MiFID II, the Senior Managers and Certification Regime (SMCR), Brexit, PSD2, and the FCA’s Consumer Duty. He also regularly assists on the regulatory aspects of mergers, acquisitions, and other strategic transactions involving regulated entities.

Arjun’s broader practice encompasses other areas of financial services regulation, including governance and accountability frameworks, financial crime compliance, the regulation of cryptoassets, buy-now-pay-later, and emerging technologies such as artificial intelligence (AI).

Arjun has undertaken secondments at both a card-based payment system and an e-money institution, providing him with valuable first-hand insight into how payment and fintech businesses operate in practice and how regulatory expectations are applied day-to-day. He draws on this experience to help clients navigate complex regulatory frameworks and implement practical, effective compliance solutions.

Recent representative matters include:

• Advising a leading global fintech company on the establishment of a new payments processing, clearing and settlement system in the UK, and on a range of ad hoc UK regulatory queries.
• Guiding various clients through the UK and EU regulatory authorization process, including the establishment of new e-money and payment institutions.
• Providing an ongoing regulatory “hotline” service to clients including an e-money issuer, a card scheme, and a UK challenger bank—advising on new product launches and regulatory compliance across areas such as safeguarding, strong customer authentication, governance, outsourcing, and the interchange fee regulation.
• Advising clients on the provision of services in the cryptoasset sector, including a major investment bank on the establishment of a cryptoasset trading desk, and an algorithmic trading firm on licensing analysis and regulatory engagement.
• Advising banks, payment systems, and fintechs on initiatives and specific directions from the Payment Systems Regulator (PSR), including the Confirmation of Payee and Authorised Push Payment (APP) Fraud Reimbursement requirements. Assisting a merchant acquiring group in assessing the impact of the PSR’s Specific Directions following its market review of the merchant acquiring sector, and supported a payment scheme in preparing its response to a PSR market study.
• Advising a UK payment system on regulatory and governance matters, including managing engagement with multiple regulators and addressing overlapping supervisory expectations.
• Advising a major UK bank on the development of its business account eligibility framework, including the ability to deny or withdraw services while ensuring compliance with regulatory obligations on objective, proportionate, and non-discriminatory access to payment accounts.
• Advising a professional services firm on a proposed partnership with a UK account information service provider to enhance its global tax and legal platform using open banking data.
• Advising an account information service provider on a range of issues, including integration with buy-now-pay-later and consumer credit products, strong customer authentication, compliance with the FCA’s Consumer Duty, and use of open banking data.
• Supporting a broad range of financial institutions on regulatory change and implementation projects, including Brexit, MiFID II, the Market Abuse Regulation (MAR), the Senior Managers and Certification Regime (SMCR), PSD2, the FCA’s Consumer Duty, and emerging reforms such as the FCA’s changes to safeguarding rules and PSD3.
• Advising numerous financial institutions on the acquisition and sale of UK regulated entities, particularly in the fintech and payments sectors.

The above matters were handled by Arjun prior to joining Sidley.