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Rory Copeland

Senior Associate

Email

rory.copeland@aoshearman.com

Phone

+44 20 3088 1573

Offices

London

V-CARD
Rory advises financial institutions, payments providers and systems, e-commerce and tech platforms and central banks on a broad range of financial services regulatory matters.

His advice focusses on new product structuring and regulatory characterisation, regulatory compliance, and rules and legislation drafting, in the areas of payment services and systems, AML and financial crime, consumer finance, financial promotions and consumer protection, and foreign exchange.

Rory advises a range of crypto-exchanges, issuers and global financial institutions on the legal and regulatory treatment of their services and impacts of legislative changes. He has advised on the development of policy and legal frameworks for the regulation of virtual assets, the issuance of central bank digital currencies, participation in cross-border CBDC networks, and the tokenising of real-world assets. He provides technical expertise for structured finance and securitisation transactions involving cryptoassets.

Rory also provides specialist support in drafting and negotiating commercial contracts and on M&A for established and growth financial institutions. He regularly assists clients with ‘change in control’ submissions associated with acquisitions of regulated firms.

Rory’s academic writing and speaking has focussed on regulatory change in payment services, fintech and virtual assets, central bank digital currencies and emerging forms of payment fraud. He is the co-authority of an upcoming book chapter on central bank digital currencies (Oxford University Press, 2024).

Experience

Representative matters

  • Numerous banks, electronic money institutions and payments institutions on all aspects of regulatory compliance for provision of a broad range of payment services, including safeguarding, strong customer authentication, customer T&Cs and emerging regimes like the Consumer Duty.
  • Numerous clients, including BigTechs, e-commerce platforms, a global banking group and a multi-currency corporate card issuer on their applications to become UK-authorised electronic money or payment institutions. This entailed drafting and review of the application documents, internal policies and the relevant Ts&Cs. We continue to provide ongoing regulatory support to these clients and have significant experience in engaging with the FCA.
  • A UK payment system operator on the structuring and drafting of a new Authorised Push Payment Fraud Reimbursement Scheme within its rulebook, as directed by the Payment Systems Regulator.
  • A global card scheme on the regulatory and contractual structuring and rulebook for a novel open-banking based payment arrangement, covering UK and EU payment systems and services, and consumer protection.
  • A UK payment system operator on the design and development of an account-to-account payments framework for Variable Recurring Payments and future use cases, in accordance with the directions of the Payment Systems Regulator.
  • Virgin Atlantic on the renegotiation of card acquiring arrangements with three card acquirers as part of Virgin’s solvent recapitalisation, and the negotiation and entry into three new acquiring agreements on novel data/reporting-driven terms.
  • Numerous ‘crypto-native’ and ‘traditional’ financial institutions on all aspects of the application of financial services, AML / financial crime, sanctions, data protection regulations to novel cryptoasset products and services, including global roll-outs, licensing projects, client documentation and regulatory engagement.
  • A global card scheme on the regulatory and contractual structuring of a global order-routing system for the purchasing and custody of interests in cryptoassets.
  • An investment firm on the structuring of an issuance of Luxembourg law governed bitcoin-linked ETF.
  • A G20 central bank on its strategy for virtual assets and a central bank digital currency, and drafting the necessary legislation to enable a licensing regime for virtual assets and the issuance of a CBDC.
  • A GCC central bank on the drafting of a virtual assets regulatory regime, including the review of payment systems laws for the use of DLT-based systems and the drafting ‘cryptoasset travel rule’ legislation. Rory on the drafting of payment services-focussed amendments to its payment services and stored-value facility regulations.
  • A GCC financial centre on the development of a real-world asset tokenisation regime, including amendments to laws governing the ownership and transfer of select asset classes and the drafting of a licensing framework.

Pro bono

  • Rory is a trustee and co-founder of Prosper, a financial inclusion charity registered in the UK and Sierra Leone which provides business training and support to woman-led businesses in West Africa. He sits on the board of the UK Financial Inclusion Forum.

Published Work

  • Copeland, Regnard-Weinrabe (2020), “Stablecoins and central bank digital currencies: a developing landscape”, Practical Law, Thomson Reuters
  • Copeland (2020), “A global stablecoin: Revolutionary reserve asset or reinventing the wheel”, Journal of Payment Strategy & Systems, Volume Thirteen, Issue Four, London: Henry Stewart Publications
  • Copeland (2020), “Virtual Asset Trading Platforms: an assessment of the stability risks and potential for self-regulation”, Journal of Digital Banking, Volume 4, Issue 3, London: Henry Stewart Publications
  • Copeland, (2018), “Regulatory revolution and new competition in the European Union payments industry", Northern Ireland Legal Quarterly, Volume 69, Issue 2, Belfast Queens University Belfast

Qualifications

Admissions

Admitted as a solicitor (Northern Ireland) 2019

Admitted as a solicitor (England & Wales) 2021

Academic

DipIPLS, Queens University Belfast, 2019

MA (Cantab), Cambridge University, 2021

BA (Cantab), Law, Cambridge University 2017

Disclaimer
A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.