Siobhan is a commercial lawyer specialising in working with businesses that provide, receive or play a role in delivering niche payment solutions. She advises clients on strategy, new product structure, business expansion, formulating procedures, regulatory conundrums and contracts (B2B and B2C).
Siobhan’s practice has a particular focus on the e-money and payment services sector, assisting fintech companies, retailers, mobile phone operators, financial institutions, e-money issuers, payment service providers, programme managers and resellers. She also liaises with regulators and government bodies on matters impacting the payment service sector.
Siobhan speaks regularly at international conferences on matters relating to e-money and payment sector.
- Retail financial services regulation
- Electronic money and payment services
- Drafting / negotiating key partner agreements
- Drafting / reviewing outsourcing / intercompany agreements
- Commercial contracts
- Customer-facing documentation
- Multi-country legal due diligence
- Multinational gift card, e-money and payment service programmes
- FCA EMI and PI applications
- FCA LNE and Change of Control notifications to the FCA
E-money and Payment Services
- Advised a startup e-money issuer on the set-up and operation of e-money programmes (product features, regulatory compliance, customer-facing documentation).
- Advised a gift card issuer on the set-up, operation and launch of an international gift card programme.
- Carried out a product review and advised on new product developments against e-money and payment service regulatory regime for a provider of a payment product.
- Carried out a multi-country due diligence project for an international bank relating to its prepaid programme (20+ countries).
- Provided regulatory advice to an international programme manager in relation to its payment service activities.
- Ran a workshop for an e-money issuer on regulatory compliance.
- Advised on Change of Control notice to the FCA relating to the acquisition of an e-money firm by an international business.
- Advised on variation of EMI and PI permission for e-money institutions and payment institutions.
- Prepared an LNE notice to the FCA for a gift card provider.
- Advised an EEA-based e-money issuer on the UK’s temporary permissions regime post-Brexit.
- Seconded to an e-money issuer to provide regulatory and contract support.
- Advised a programme manager on the migration of e-money accounts and cards from its appointed e-money issuer to a third-party provider.
- Drafted BIN Sponsor agreement for an e-money issuer offering card scheme and e-money sponsor services.
- Negotiated key partner agreements (BIN Sponsor agreement, transaction data processing agreement and white label partner agreement) for a new business entering the prepaid card/e-money market.
- Drafted and negotiated an agreement for the provision of a faster payments scheme service by a credit institution for an e-money issuer.
- Drafted an outsourcing agreement for a payment institution for provision of outsourced services.
- Drafted an inter-company agreement for an e-money issuer relating to the provision of IT and certain operation functions by another company in its group.
- Drafted a distribution agreement and white label partner agreement relating to the distribution of e-money products for an e-money issuer.
- Drafted a retailer agreement for the provision and acceptance of gift cards for a gift card issuer.
Please note: The experience list above may include examples of work completed prior to joining Keystone Law.
Board Member, Executive Committee, Gift Card and Voucher Association (GCVA)
Director, Prepaid International Forum (PIF)
Siobhan qualified as a solicitor in 2002. Prior to joining Keystone Law in 2021, she worked at the following firms:
- Locke Lord (UK) LLP
- Salans LLP
- Osborne Clarke LLP