Siobhan Moore

Siobhan supports e-money and payment service providers on multinational gift card and payment programmes, customer-facing documentation, and FCA applications, offering strategic advice on cross-border compliance and innovative payment models.

• 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.
• 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 variation of EMI and PI permission for e-money institutions and payment institutions.
• 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.

Siobhan drafts and negotiates key partner, outsourcing, and intercompany agreements, with expertise in commercial contracts for FinTechs and payment providers, including terms for customer-facing platforms and global product rollouts.

• 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.

Siobhan advises financial services clients on FCA EMI and PI applications, LNE and Change of Control notifications, and multi-country legal due diligence, particularly across FinTech and regulatory compliance matters.

• Carried out a multi-country due diligence project for an international bank relating to its prepaid programme (20+ countries).
• Advised on Change of Control notice to the FCA relating to the acquisition of an e-money firm by an international business.
• Prepared an LNE notice to the FCA for a gift card provider.

Board Member, Executive Committee, Gift Card and Voucher Association (GCVA)

Director, Prepaid International Forum (PIF)