Writing in the Financial Times Huw van Steenis, former adviser to the governor of the Bank of England and chair of the sustainable finance committee at UBS, says the time is now to update payments rules; the payments system was once done under the roof of a bank but has since changed to include various parties that are interdependent; the Wirecard scandal and the increase in card usage due to the pandemic make time of the essence to change how the sector is regulators; Simon Gleeson of Clifford Chance argues in his book, The Legal Concept of Money, that regulators should be focused on activities instead of entities; as companies grow in size they should be looked at and regulated accordingly to cut down on systemic risk; Singapore has brought this approach to their system as they now have three tiers of payments companies; Steenis writes that payments companies should be forced to pen living wills, “That requirement should now be applied to payments companies that are deemed systemic, with clear segregation of funds to ensure smooth transitions and alternatives for businesses and consumers.” Financial Times.
