Financial Services

We help clients anticipate change and innovate across the product lifecycle – from launch to funding, growth to disposals. In a fast-moving sector, our deep industry knowledge and clear, pragmatic advice makes the difference.

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Our Financial Services Regulatory team is recognized as an industry leader with deep sector knowledge and a proven ability to put regulation in context, help clients innovate through change, engage strategically with regulators, and challenge decisions with confidence.

Acting across the entire ecosystem and product lifecycle, we have a unique perspective. Supporting start-up FinTechs, institutional, global banks and asset managers with everything from funding, product launch and regulatory interventions to acquisitions or disposals, and the use of new technology, including AI, we are involved and understand the issues. With significant breadth and depth, we break through regulatory and legal silos to deliver practical, commercially focused solutions.

We stay ahead of the curve, anticipating market disruption and shaping the regulatory and policy environment to our clients’ advantage. Our collaboration with regulators, industry bodies, and market participants allows us to share insights on interpreting and applying new regulations, provide experience on existing regimes, and help predict future trends.

With a strong global presence, we bring this depth of experience to the leading markets in Europe, the United States, and Asia. Our clients include commercial and investment banks, institutional asset managers, insurers, card issuers, e-money providers, payment service providers, technology platforms, pension funds, retail and private wealth managers and investment advisers, broker dealers, trading platforms, financial market infrastructure, digital assets platforms and service providers, commodities traders, investment and insurance intermediaries and rating agencies.

Consumer Finance

FinTech

Digital Assets and Blockchain

Investment Products and Services

Financial Market Infrastructure

Payment Services

Dealing with Financial Services Regulators

Governance

Product Distribution and Outsourcings

Authorizations

We regularly advise a wide range of financial institutions on the FCA’s rules governing the holding and use of client money and client assets (CASS).

This not only includes advising on how to comply with the CASS rules on an ongoing basis, but also on the options for structuring arrangements for handling and holding clients’ monies and assets in order to identify the optimal model. This may include advice on how best to structure arrangements with third parties who are involved in the transmission or holding of clients’ funds and assets, advice on systems and controls, negotiation of custody agreements, or advice on what restrictions apply to the use of client assets.

We are also able to advise on the implications for a firm’s client assets in the event of an insolvency, including what to do to protect clients’ interests and ensure compliance with the FCA’s rules on distribution.

We are the go-to firm for consumer finance launches and compliance, assisting clients with a number of market firsts. We help clients with secured and unsecured loans, credit cards, buy now pay later and embedded finance, merchant finance and mortgages.

As well as advising on product terms and processes, we routinely advise on funding and securitization arrangements, debt sales, and regulatory and consumer challenges in this space.

Empowering innovation across payments, lending, and digital financial services, we guide clients through evolving regulatory frameworks and emerging technologies to help them scale securely and confidently in a fast moving FinTech landscape.

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Providing advice on tokenization, custody, and compliance, we help clients innovate securely in the evolving digital asset and blockchain ecosystem.

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We regularly advise both retail and wholesale investment firms on their development and provision of investment products and services.

This may include assisting firms to understand the regulatory requirements applying to their investment products and services and how operationally and legally to implement their investment offering.

Such tasks may range from developing compliance procedures, drafting product and service terms and conditions, and negotiating arrangements with service providers and market counterparties.

Given the breadth of our experience, we are able to provide regulatory advice on all aspects of the life-cycle of a firm’s investment activity, from issuance or trading, to risk management and settlement of an investment transaction.

We are a leading firm in the field of financial market infrastructure, advising some of the world’s most significant FMI groups on a wide range of legal and regulatory matters. This includes advising on the establishment and authorisation of new FMIs, such as our work on the establishment of a number of significant central counterparties and on the development and maintenance of rulebooks for multiple investment exchanges, CCPs, and settlement systems.

We help FMI operators to determine how best to bring new products and functionality to market, including how to mitigate risks of challenge by regulators, market participants, and other third parties.

We also help FMI operators during times of crisis, whether arising from operational outages or external events such as disorderly market conditions. This may include assistance with complaints, investigations or litigation, and any remediation work designed to reinforce the resilience of these market-critical systems.

In addition to advising the FMIs themselves, we are also perfectly placed to advise market participants on their own arrangements for accessing and using the services of FMIs.

We regularly advise payment institutions and banks on their payment offerings. This includes payment accounts, money remittance services, and card issuing and merchant acquiring.

We have assisted with novel payment use cases, including the first introduction of digital wallets and the application of payment regulations to wearable or embedded products.

We have helped institutions across Europe comply with PSD2 and SEPA requirements and regularly advise on card scheme rules and interchange requirements.

We have good relationships with regulators and legislators around the world and routinely help our clients to engage with regulators and Government.

We help clients navigate and influence regulatory change as it applies to their business, including by helping them engage with Government and regulators. We also support our clients through regulatory engagements and enforcement actions.

We help our clients to navigate the various laws and regulations relevant to the governance of financial institutions, including corporate laws on the operation of boards and the duties of directors, and the regulatory regimes applying to senior managers.

This may include helping firms to establish the policies and procedures to enable them to comply with these legal and regulatory requirements and undertaking reviews of the structure and effectiveness their governance arrangements.

We assist with applications for regulatory approval of senior managers and the preparation for individual interviews with the regulators. In the event of adverse events occurring, where the conduct of individuals or the effectiveness of governance arrangements may be scrutinized, we help firms to determine how best to engage with their regulators and on any subsequent remediation activities.

We help our clients with their regulated commercial arrangements. This includes distribution agreements, co-brand, white labeling, or partnership arrangements to get products to new distribution channels. In the cards space, it also includes merchant agreements and card scheme agreements on both the issuing and acquiring side.

We also assist on outsourcings and regulatory compliance, including undertaking projects relating to EU and UK outsourcing guidance and operational resilience requirements such as DORA.

We assist on the development and negotiation of critical outsourcing agreements for regulated firms, including buyers of outsourced services and service providers themselves. We help our clients to ensure that such agreements meet regulatory requirements and expectations, and also represent a commercially balanced, and robust contractual framework to govern the provision of important services.

We support clients through their application journeys, advising holistically on product design, regulatory permissions, prudential and conduct concerns, the authorization journey and documents, and policies and procedures.

We do this through a combination of legal and consulting professionals within a single team. Our work in this area has included banks, investment firms, consumer finance firms, payment institutions, e-money institutions, virtual asset service providers, and crypto asset service providers.

Hear from our clients and industry leaders

Hogan Lovells’ financial regulatory practice is considered the top practice for financial technology and payment services."

Financial Services client testimonial 2025

The team has market-leading expertise and great people who combine first-rate legal advice with a commercial approach."

Financial Services client testimonial 2024

Fantastic to work with."

Financial Services client testimonial 2025

The work product is excellent."

Financial Services client testimonial 2024

They are a breath of fresh air and are expert corporate advisers."

Financial Services client testimonial 2024

Have deep understanding and experience in payments, and are adept at providing pragmatic advice."

Financial Services client testimonial 2024

Keenly aware of businesses’ commercial and stakeholder needs."

Financial Services client testimonial 2024

Go-to for consumer credit work."

Financial Services client testimonial 2023

Always alive to the business perspective and what the business is trying to achieve."

Financial Services client testimonial 2023

Deliver advice in a clear, practical and commercially sensible manner."

Financial Services client testimonial 2023

They are collaborative and have a bespoke approach."

Financial Services client testimonial 2025

The team has very strong commercial acumen which is great when trying to navigate through knotty legal issues."

Financial Services client testimonial 2024

Advice is thoughtful and responsive but also direct and solution-focused."

Financial Services client testimonial 2024

Deep knowledge and experience in the retail regulatory area, in particular consumer lending. The quality of advice and responsiveness ranks them ahead of the other firms."

Financial Services client testimonial 2025

Outstanding level of client oriented service."

Financial Services client testimonial 2025

Quickly becoming a leader in the digital assets space."

Financial Services client testimonial 2025

Key contacts

Jonathan Chertkow

Partner

Jonathan Chertkow

Partner

London

Michael Thomas

Partner

Michael Thomas

Partner

London

Dr. Richard Reimer

Partner

Dr. Richard Reimer

Partner

Frankfurt

Sara C. Lenet

Partner

Sara C. Lenet

Partner

Washington, D.C.

Jeffrey Greenbaum

Partner

Jeffrey Greenbaum

Partner

Rome

Meet the Financial Services team

Representative experience

Monzo

The challenge

A UK digital bank required legal advice to support its strategic expansion with regard to both the services it provides and the geographies in which it operates.

Our solution

Advised the client on expanding beyond its core banking and lending propositions into investment services, including online securities dealing, and robo-advice. To achieve this, the client had to apply to the PRA for a formal variation of permission (VOP). Our role included advising on the legal requirements, assisting with the drafting of the VOP application and supporting documentation, and advising on key contracts with third parties, such as the outsource provider of services to the client and the provider of funds to the platform.

London

The London Metal Exchange

The challenge

In March 2022, an unprecedented and volatile situation took place in the LME nickel market which resulted in the LME suspending the market and cancelling trades that had taken place during the morning of 8 March 2022. This decision led to a series of high-profile court cases for the LME, which turned to Hogan Lovells as their longstanding, trusted advisor to defend them.

Our solution

Acted for the LME in high profile judicial review claims brought by Elliott Associates and Jane Street, challenging the decisions made by the LME on 8 March, by which the Claimants sought approximately US$470 million in damages under the Human Rights Act. We secured resounding victories for the LME, at both the Divisional Court and on Elliott’s subsequent appeal to the Court of Appeal, affirming that the LME’s actions were lawful, justified, and proportionate.

This case builds on many years in which we have supported the LME on a wide range of legal and regulatory matters, including the launch of its clearing house, LME Clear, the group’s adaptation to new regulatory requirements (including EMIR, MiFID II, Benchmark Regulation and Brexit) and the evolution of its trading and clearing arrangements over time.

International Banking Group

The challenge

An overseas-headquartered bank, and longstanding key client of the firm, aimed to support its strategic expansion through the establishment of a UK and European digital bank.

Our solution

Supported the launch of the bank and the subsequent roll out of new products in the UK, including the development of retail investment services.

Our involvement has included structuring advice, regulatory advice on the UK’s regime, dealing with regulatory approvals, drafting and reviewing customer-facing documentation and communications, reviewing impacted bank processes and procedures, and reviewing customer journeys.

We have subsequently advised the client on its plan to launch in Germany and provide consumer banking and investment products and services across Europe using European passporting rights.

Support has included conducting jurisdictional analysis of different European jurisdictions for the purposes of establishing a European base; engagement with European regulator BaFin in relation to licensing; advice on the core legal and regulatory requirements that will apply to the products and services the bank intends to provide; as well as product development work to operationalize their delivery.

Awards and recognitions

Financial Services Regulatory Team of the Year

IFLR Europe Awards

2025

Fintech Firm of the Year

Chambers & Partners UK Awards

2025

Banking and Finance Law Firm of the Year

JUVE

2024

Band 1 in Financial Services: Payments Law

Chambers UK

2025

Band 1 in Consumer Finance

Chambers UK

2025

Band 1 in Blockchain & Cryptocurrencies

Chambers FinTech Legal

2025

Band 1 in Payments & Lending

Chambers Fintech Legal

2025

AMLA Hub

Our interactive AMLA Hub serves as a central resource covering the latest trends and developments. Explore the Hub to assess how the EU AML regime applies to you, find our recent thought leadership, navigate new laws and regulations, and to get in touch with our market-leading AML team.

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