The Central Bank of Ireland has outlined the protection of consumer assets to be a ‘’key priority’’. The regulator requires firms, in order to become authorised as a payment or e-money institution, they must have in place adequate mechanisms to protect consumer funds through ‘’safeguarding’’.

As such, applicant firms must hold funds received from consumers for payment/e-money services separately from other funds and place them in a special account held within an EEA authorised bank, or to cover the funds with an insurance or guarantee policy.

Firms must abide by the safeguarding requirements as stipulated by the EU Second Payment Services Directives (PSD2) as well as the Electronic Money Directive, as implemented through the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1) Investment Firms Regulations 2017).

Key Takeaways:

1. The requirements and obligations within the Payment Services Regulations 2018 (PSRs ) and the Electronic Money Regulations 2011 (EMRs).
2. What does the CBI expect in relation to safeguarding customers funds in payment and e-money institutions when getting authorised and from a supervisory point of view.

Speaker:

Alison Donnelly, Director, fscom
Alison is a payments policy expert with in-depth knowledge and understanding of the payments regulatory landscape.
She is a former FSA/FCA e-money policy specialist and shares this insight from the regulator to clients and contacts alike in her role as Director in fscom providing compliance advice to leading fintech companies and start ups.
Alison is Leader of the Emerging Payment Association’s (EPA’s) Project Regulator which aims to engage with regulatory bodies to promote and champion the concerns of EPA members in current and future regulation, and drives change through the development of a fairer regulatory landscape for payments companies. Alison is also on the Board of Directors of the Association of Professional Compliance Consultant (APCC) and has also recently been appointed as EWPN Ambassador for Ireland.
With a career background in policy development and influencing, Alison applies her experience and skills to work with clients and strategic stakeholders.

Russell Burke, Independent Payments Consultant
Russell Burke, independent payments consultant, with a unique combination of extensive regulatory and strategic experience, is one of Ireland’s leading payments specialists with over forty years’ experience with the Central Bank of Ireland, the Irish Payments Services Organisation (IPSO) and Bank of Ireland.
Specialising in payments since 2000, Russell most recently helped transform the regulated payments sector in Ireland over seven years as the Senior Payments Specialist with the Central Bank of Ireland’s Payments Authorisations Team assessing and making decision recommendations for the many payments and electronic money firms now authorised in Ireland e.g. Facebook, Google, Stripe.
Before that, Russell headed Strategic Development at IPSO, now Banking and Payments Federation of Ireland, for seven years, which included two years on secondment to the Government’s National Payments Plan where he led its mobile payments and cheque reduction programmes. He previously held a number of key payments-related roles in Bank of Ireland where his responsibilities included strategy, innovation and European affairs and he headed the bank’s Group SEPA Implementation Programme.
Russell represented Ireland on the European Payments Council’s Mobile Channel Expert Group for four years, was a member of the Department of Finance’s Financial Inclusion Task Force, was a member of the National Payments Implementation Programme Advisory Group and was a director of the global industry association, Mobey Forum, for four years, serving two as deputy chair.
Russell has been a speaker at a number of major domestic and international events and, more recently, has spoken on behalf of the Central Bank of Ireland at several industry events on the application and authorisation processes for payments and electronic money institutions in Ireland.
Russell has an MBA from the UCD Michael Smurfit Graduate Business School, is a qualified financial adviser and a licentiate of the Institute of Banking in Ireland.