PSD2 – related advisory services – a 2019 summary

The end of the year invites summaries. In the field of financial services regulation, 2019 was primarily the year of implementation of the new Payment Services Directive (PSD2) and of the accompanying technical standards (RTS). We extend our thanks to the Clients who have trusted us in this pioneering adventure:

  • 8 banks to whom we have advised on PSD2 implementation – including 3 from the first five;
  • 6 API legal audits connected with the exemption from the obligation to create a fall-back interface;
  • 5 proceedings to exempt corporate processes from the requirement to use SCA;
  • 2 legal audits of the SCA implementation;
  • 1 of 2 advisors on the Polish API (greetings to the @Bird & Bird colleagues) – we have focused on the fallback interface;
  • the sole PSD2 advisor to the Banking Law Council at the Polish Banks Association.

The work was performed by 6 lawyers of the SK&S financial services regulation team (Wojciech Iwański, Mateusz Blocher, Katarzyna Janczewska, Lidia Malinowska and Filip Bachowski, headed by Marcin Olechowski), and by 3 lawyers representing the personal data protection team (Katarzyna Paziewska-Młodawska and Rafał Sokół, managed by attorney Agata Szeliga).

And we have only just embarked on the path of  “open banking”.

SK&S Legal

SECURITY ALERT

Dear Sirs,

We would like to inform you that in recent days, fraudulent emails impersonating our law firm have appeared online. In some cases, these emails include alleged invoices issued by SK&S.

Such fraudulent emails can be identified as they are sent from unusual, unknown addresses that do not belong to our domain. Additionally, these messages are often sent from addresses deceptively similar to those of legitimate senders. We want to emphasize that our law firm has no connection to these emails. All official correspondence from us is sent exclusively from addresses within the domain @skslegal.pl.

We have reported this matter to the Police, specifically to the Central Bureau for Combating Cybercrime, due to suspicions of criminal activity. Please exercise caution: carefully verify the sender’s address and avoid opening any suspicious emails or attachments. If in doubt, we recommend deleting such correspondence immediately.