
Trump Administration Executive Order (EO) Tracker
Key developments of interest over the last month include: the UK government publishing a pro-growth Action Plan for regulators and regulation, including pledges from the FCA of relevance to payments and digital assets firms; the signing of a U.S. Presidential Executive Order establishing a Strategic Bitcoin Reserve and a U.S. Digital Asset Stockpile; and the German Federal Financial Supervisory Authority (BaFin) releasing a consultation paper outlining the responsibilities of depositaries and capital management companies managing investment funds that invest in cryptoassets.
In this Newsletter:
For previous editions of the Payments Newsletters, please visit our Financial Services practice page.
The European Payments Council (EPC) announced on 6 March 2025 that the Republic of North Macedoniaand Moldova have joined the Single Euro Payments Area (SEPA) payments schemes. This allows existing SEPA participants to send and receive SEPA Credit Transfers (SCT), SEPA Instant Credit Transfers (SCT Inst), and SEPA Direct Debits (SDD) with financial institutions in these countries once they adhere to the schemes.
Financial institutions from North Macedonia and Moldova will be able to join the SEPA schemes from April 2025, with full operational readiness expected by 5 October 2025. The SEPA payment schemes now cover 40 countries.
On 12 March 2025 (press release dated 11 March), the UK government announced its intention to consolidate the Payment Systems Regulator (PSR) and its functions primarily within the FCA. The Economic Secretary to the Treasury has also written to the Treasury Committee (and the House of Lords Financial Services Regulation Committee) to provide further detail on the announcement.
This is part of the government's Plan for Change, aiming at 'a more streamlined regulatory environment' with 'minimal overlap between regulators’ responsibilities'. The idea is that, as a result of the consolidation, payments firms will be able to 'focus more of their resources on delivering valuable services and innovations that will deliver on the government's central growth mission'.
The government will consult on the details of the proposal over the summer, and will legislate as soon as possible. In the meantime, the PSR and the FCA will take steps to work closely together, building on the recent recruitment for a joint PSR/FCA payments executive director. Statements have also been released by the FCA and the PSR.
Following the announcement about the consolidation of the PSR within the FCA, on 17 March HM Treasury published a related policy paper containing an Action Plan for “A new approach to ensure regulators and regulation support growth”. See the below separate item for more on the Action Plan.
On 14 March 2025, the FCA published an engagement paper seeking feedback on potential changes to contactless payment limits. Currently, the limit is £100 per transaction or £300 across multiple payments (or no more than 5 consecutive contactless transactions) before authentication is required.
The review has been expedited by the government’s pro-growth agenda (see the separate item on its recently published Action Plan), and the FCA makes reference to its secondary international competitiveness and growth objective. Among other things, it suggests that enabling more contactless payments could have positive secondary impacts on growth, through smoother consumer payment journeys resulting in more sales and higher productivity.
The FCA is looking for views on the following options for change (but also allows for the possibility of keeping things as they are):
The FCA is also open to considering any alternative options that have not been raised in the paper.
In addition, the FCA sets out how this work fits in with its wider review of strong customer authentication (SCA) in accordance with the 2024 National Payments Vision (NPV). Take a look at this Our Thinking article for more on the NPV.
The deadline for feedback on the engagement paper is 9 May 2025, with consultation on any revised standards, rules or guidance to follow.
Take a look at this Our Thinking article for more on this development.
Following the publication of the FCA’s engagement paper, on 17 March HM Treasury published a related policy paper containing an Action Plan for “A new approach to ensure regulators and regulation support growth”. The engagement paper is one of the FCA’s short-term (ie implementable within the next 12 months) pledges under the Action Plan. See the below separate item for more on the Action Plan.
On 17 March 2025, HM Treasury (HMT) published a policy paper containing an Action Plan for “A new approach to ensure regulators and regulation support growth”. The Action Plan sets out the next steps to the government’s approach on regulation and regulators, and contains three main action points:
The Action Plan includes a range of pledges from key regulators – including the FCA and the PRA - to support the growth effort. Some of the FCA’s pledges of particular relevance for payments and digital assets firms are to:
The aim is to enable a regulatory system that supports innovation and economic growth while ensuring accountability for the quality of regulations introduced, as well as the way in which independent regulators implement and enforce them.
Take a look at this Our Thinking article for more on the financial services aspects of the Action Plan.
In this Our Thinking article, our Digital Assets and Blockchain team set out some thoughts on what the recent UK policy announcements mean for digital assets and blockchain.
On 17 March 2025, UK Finance (UKF) announced the publication of its 'Plan for Growth', setting out reforms that it considers are needed to help the UK's financial services sector make an even stronger contribution to the government’s growth agenda, while also delivering real benefits for consumers, businesses and society.
There are some immediate, near-term and long-term reforms that UKF believe should be prioritized. Some of these are summarised below:
On 3 March 2025, the Payments Association released its Payments Manifesto 2025, urging the UK government to implement 66 policies recommended by payments professionals to drive growth in the UK’s payment systems.
Key points include:
The manifesto stresses the need for urgent action to maintain the UK’s leadership in payments and prevent falling behind the U.S. and EU in emerging technologies.
On 28 February 2025, the Central Bank of Ireland (CBI) announced the publication of its Regulatory and Supervisory Outlook Report 2025(Report). The Report outlines key risk topics which the CBI deems to be most material from a supervisory perspective across the banking and payments sectors.
Key risks identified for the Payments and E-money sector include:
Key supervisory activities for the Payments and E-money sector include:
Take a look at this Our Thinking article for more on this development.
On 11 March 2025, the European Central Bank (ECB) published an announcement regarding the launch of a verification of payee (VoP) service for payment service providers (PSPs). This service will assist PSPs in the Single Euro Payments Area (SEPA) to meet the requirements of the Instant Payments Regulation (IPR), which mandates that payers be informed of any discrepancies between the payment account number and the intended payee's name before initiating a payment.
The VoP service, developed by Banco de Portugal and Latvijas Banka, aligns with the European Payments Council's (EPC) VoP scheme. It will be available for both instant payments and SEPA credit transfers.
On 6 March 2025, the Payment Systems Regulator (PSR) published its final report on its market review into card scheme and processing fees.
Key findings include:
In terms of next steps, the PSR will shortly consult on potential remedies to address the issues that it has found, including measures to improve transparency and competition in the market.
In parallel, the PSR has been conducting a market review into cross-border interchange fees. A final report and remedies consultation were published in December 2024. Take a look at the January 2025 edition of the Newsletterand this Our Thinking article for more information.
On 11 March 2025, the Payment Systems Regulator (PSR) published a policy statement (PS25/3) and accompanying webpage regarding the publication of 2024 authorised push payment (APP) scams data, along with considerations for future reporting. This follows the introduction of the mandatory APP fraud reimbursement requirement on 7 October 2024. The PSR plans to publish two updates for 2024:
In terms of next steps, the PSR is planning to carry out a call for views on future data reporting in spring 2025, where it will engage with stakeholders to ensure that its future reporting aligns with consumer needs, regulatory requirements, and its commitment to transparency. Key considerations will include whether it reports at the firm or industry level, the frequency of future reporting, and the potential inclusion of additional metrics that may provide further insights into the nature and impact of APP scams, such as time taken to close cases and reasons for customers being deemed grossly negligent. The PSR will communicate any changes to the reporting structure well in advance to allow stakeholders to prepare for new data and metrics.
The PSR explains that the structure and scope of future updates will depend in part on the timing and approach to the implementation of reporting standard B on which the PSR will seek input as part of an upcoming consultation planned for April 2025.
On 27 February 2025, the U.S. Securities and Exchange Commission (SEC) issued a staff statement where they clarified that meme coins are not considered securities under the Securities Act of 1933. This decision follows the rise of meme coins, such as the $Trump coin, which have gained attention due to their speculative nature and price volatility. The SEC explained that transactions involving meme coins do not require SEC registration, as they do not meet the criteria of the Howey Test for investment contracts. Classified as collectibles, meme coins are primarily driven by market demand and speculation, rather than any business enterprise or expectation of profit from others' efforts. However, the SEC warned that fraudulent conduct related to meme coins could still face enforcement under other laws.
On 3 March 2025, the SEC announced in a press release that its Crypto Task Force will host a series of roundtables as part of the "Spring Sprint Toward Crypto Clarity" initiative. The first session, titled "How We Got Here and How We Get Out – Defining Security Status," was due to take place on 21 March 2025. A recording will be available later. Details of panelists can be found here.
On 10 March 2025, SEC Acting Chairman Mark T. Uyeda remarkedthat the Commission is reconsidering its 2022 proposal to regulate crypto firms under its oversight of alternative trading systems (ATSs). Uyeda requested staff to evaluate abandoning the proposal in response to significant negative public feedback. The original plan sought to redefine ATS regulations to include crypto platforms, but concerns over expanding regulatory definitions have led the SEC to reassess the approach. The Commission will now engage with other federal agencies and market participants to determine the best course of action.
On 7 March 2025, the U.S. Office of the Comptroller of the Currency (OCC) issued Interpretive Letter 1183, clarifying that certain cryptocurrency activities, including crypto-asset custody, stablecoin services, and participation in independent node verification networks (such as distributed ledgers), are permissible for national banks and federal savings associations. The letter rescinds the previous requirement for these institutions to receive supervisory non-objection before engaging in such activities. The OCC emphasised that banks must still manage these activities with appropriate risk controls, ensuring compliance with relevant laws and regulations. This action aims to reduce regulatory burdens and promote innovation while maintaining a safe and sound banking system.
On 10 March 2025, Thailand's Securities and Exchange Commission (SEC) published an announcement approving Tether's USDT and Circle's USDC stablecoins for trading on digital asset exchanges with effect from 16 March 2025. This decision expands the list of approved cryptocurrencies, which previously included Bitcoin, Ethereum, XRP, Stellar, and select tokens used by the Bank of Thailand. The move aligns Thailand with global trends as stablecoins play a larger role in crypto trading and payments.
The following Markets in Crypto-Assets Regulation (MiCA) related documents have been published recently:
If there are no objections from the Council of the EU or European Parliament, the Delegated Regulations will be published in the Official Journal of the EU and will come into force 20 days after publication.
On 28 February 2025, the Cayman Islands introduced updates to its cryptoasset regulatory framework through the publication of the Virtual Asset (Service Providers) (Amendment) Regulations 2025. The new regulations, effective from 1 April 2025, strengthen licensing requirements for virtual asset custodians and trading platform providers. These updates are part of broader enhancements introduced alongside the Virtual Asset (Service Providers) (Amendment) Act 2024, aiming to improve investor protection and market integrity within the jurisdiction.
On 28 February 2025, the ECB published Contribution to Bancaria by Piero Cipollone, Member of the ECB's Executive Board, based on remarks at the Crypto Asset Lab Conference on 17 January 2025.
Mr Cipollone underscores the importance of developing a digital equivalent to central bank money, both for retail ("digital euro") and wholesale transactions. He also highlights the Eurosystem's ongoing efforts to integrate digital solutions into Europe's financial system, ensuring the euro remains competitive and resilient in the digital age.
Key points include:
On 6 March 2025, President Donald J. Trump signed an Executive Order establishing a Strategic Bitcoin Reserve and a U.S. Digital Asset Stockpile - see this White House fact sheet. The Reserve will be capitalised with Bitcoin already held by the U.S. government, primarily from past forfeiture actions, while the Stockpile will include other digital assets such as Ether (ETH), XRP, Solana (SOL), and Cardano (ADA), all similarly acquired through forfeiture proceedings.
The Executive Order makes clear that no new Bitcoin purchases will be made for the Reserve at this stage. However, future acquisitions may be authorised, provided they do not impose additional costs on U.S. taxpayers. The Reserve is intended to serve as a long-term store of value, positioning Bitcoin as a reserve asset similar to how gold is stored in Fort Knox.
This move highlights the administration's intent to enhance the role of digital assets within the U.S. financial system and support broader adoption of cryptocurrencies while safeguarding taxpayer interests.
On 4 March 2025, the U.S. Senate passed a resolution to repeal the IRS’s "DeFi Broker rule," which imposed tax reporting requirements on certain DeFi participants. The move, led by Senator Ted Cruz (R-Texas), is supported by key industry players, according to a letter (dated 19 February 2025) from the Blockchain Association to Members of Congress. This development was first highlighted in our February 2025 Newsletter.
On 5 March 2025, Clyde Vanel, Chair of the New York Assembly’s Banks Committee, introduced Bill A06515. The bill proposes criminal penalties to combat cryptocurrency fraud, including illegal rug pulls, private key fraud, and the failure to disclose interests in virtual tokens, aiming to enhance investor protection.
On 25 February 2025, the German Federal Financial Supervisory Authority (BaFin) released a consultation paper outlining the responsibilities of depositaries and capital management companies managing investment funds that invest in crypto assets:
The consultation closes on 31 March 2025. Stakeholders are encouraged to submit feedback to help refine the final guidelines. Take a look at this Our Thinking article for more information.
On 12 March 2025, the Master of the Rolls, Sir Geoffrey Vos, delivered a speech to the LawTech UK Conference 2025, outlining three new projects on which the UK Jurisdiction Taskforce (UKJT) is engaged:
The UKJT is working on the formation of an International Jurisdiction Taskforce. The aim is to bring together experts from the major private law jurisdictions to explore possible private law alignment between those jurisdictions in the context of digital assets and digital trading.
On 10 March 2025, Riksbank, Sweden’s central bank, announced that they are prioritising work on improving the possibility of making offline payments by card in the event of major disruptions in data communications. At the same time, Riksbank governor, Erik Thedéen, encouraged the public to strengthen their payment preparedness by having both physical cards and cash available to use.
Currently, the ability to pay offline in Sweden is limited and doesn’t work at all for contactless and mobile wallet payments.
Riksbank aim to implement a solution allowing offline payments by 1 July 2026.
On 4 March 2025, it was reported that Wizz Air has partnered with Revolut to allow customers to buy airline tickets in one click when they use Revolut Pay in the WIZZ app. At the same time, Revolut customers will be able to turn their RevPoints into air miles. This partnership aims to make the process of buying tickets more secure, efficient, and streamline the checkout experience.
On 5 March 2025, Expedia Group announced their plans to introduce Flex Pay, a BNPL solution, to travelers booking cruises in the United States and Canada. With the introduction of Flex Pay, Expedia Group aim to offer more affordable payment options, allowing customers to book their dream cruise.
On 7 March 2025, it was reported that financial technology company Lili Connect is now available to international businesses and entrepreneurs who are not U.S. residents. This expansion will allow corporate formation services partners to be able to leverage Lili’s services and streamline their banking, accounting and tax preparation products. In addition, they will be able to benefit from Lili’s international wire payments service, bill pay service, and invoicing software.
On 5 March 2025, Emirates NBD published a press release announcing that they are to be the first bank in the UAE to introduce the Visa Commercial Pay-Mobile Module for their SME and corporate clients.
Visa Commercial Pay-Mobile allows corporates and SMEs to manage expenses and allows employees to make payments using Visa virtual cards on their mobile phones through digital wallets. This solution also allows virtual cards to be used for point-of-sale (POS) transactions.
On 10 March 2025, it was reported that TerraPay, a money movement company, has partnered with Banque du Caire, a financial institution in Egypt, to offer digital payouts to all bank accounts and digital wallets across Egypt.
Remittances from the Egyptian diaspora worldwide are a major source of foreign currency, estimated at around $30 billion annually. This partnership aims to offer faster, cost-efficient and more secure remittance services.
On 5 March 2025, Nexi Group, a European PayTech, announced that they have collaborated with WeChat Pay to allow Swiss merchants to accept payments at point-of-sale (POS) through the WeChat Pay App.
Nexi Group explains that Switzerland is a top European destination for Chinese tourists who spend an average of €400 a day when travelling. This presents an opportunity to Swiss merchants to boost sales by offering payment services tailored to the preferences of Chinese tourists. It is also an opportunity to enhance the shopping and purchasing experience for Chinese tourists.
On 10 March 2025, it was reported that Razorpay had expanded its operations into Singapore, its second market in Southeast Asia after Malaysia. Businesses in Singapore can now access a range of services including payment gateway, cross-border transaction solutions, and real-time financial analytics.
A Razorpay official noted that Singapore’s advanced digital economy makes it a strategic location for their expansion. Razorpay anticipate considerable growth in Southeast Asia’s digital payments sector, with transaction volumes projected to exceed $2 trillion by 2030. Singapore is expected to be an important driver of this growth.
On 6 March 2025, it was reported that BVNK, a stablecoin payment infrastructure provider, had launched an embedded wallet that “unifies” fiat and stablecoins worldwide. The embedded wallet aims to offer scaled payment flexibility for businesses and customers allowing users to pay in and pay out in both fiat and stablecoin/crypto using a single platform. Additionally, the wallet will allow users to gain access to blockchains and payment schemes such as Swift, SEPA, and ACH.
On 12 March 2025, it was reported that Coinbase had secured registration with India’s Financial Intelligence Unit, allowing Coinbase to offer their crypto trading services in India. Following this, Coinbase plan to launch their initial retail services later this year, followed by additional investment and products in India.
On 5 March 2025, the digital asset security platform Fireblocks announced that they have launched a Cyber and Operational Resilience (COR) compliance package designed to help financial institutions meet the European Union’s Digital Operational Resilience Act (DORA) obligations. The COR Compliance Package is designed for institutions that designate Fireblocks as a Third-Party ICT Provider and includes a dedicated legal addendum, annual and periodic reports, an advanced ICT security kit, and an annual security pooled audit event.
On 4 March 2025, it was announced that BankPozitif, a Turkish investment bank, had partnered with Taurus, a Swiss FinTech, to expand its capabilities into digital assets and cryptocurrency services. This collaboration makes BankPozitif the first Turkish digital bank to implement institutional-grade digital asset infrastructure amid growing demand.
Through this collaboration, BankPozitif is rolling out a digital asset custody platform for cryptocurrencies, tokenised assets, and digital currencies. They are also implementing a blockchain node and indexing infrastructure enabling connectivity to both public and permissioned blockchains.
On 3 March 2025, The Paypers published its Global Payments and Fintech Trends Report 2025. The report explores how geopolitical tensions, emerging risks, artificial intelligence, and fintech innovations are shaping the global financial landscape. Additionally, the report examines the evolution of payment infrastructure and digital identity trends.
Findings reveal that geopolitical tensions have influenced funding availability. Asia is rapidly expanding its funding sources while Europe has experienced fluctuations. This makes the decision on where to seek funding more complex.
Some other points from the report include:
In March 2025, the Federal Reserve released its latest Federal Reserve Payments Study (FRPS), covering trends in non-cash payments for the years 2015, 2018, and 2021. Key findings from the study include:
On 10 March 2025, KPMG published their ‘Digital Assets in Germany 2025’ study. The study was conducted with over 2,400 participants and examined the investment behaviour and preferences of crypto investors in German-speaking countries. Key findings from the study include:
Around 80% of investors in their first year trade cryptoassets at least once a month whilst more than a third of experienced investors limit their trading to quarterly or less frequently.
Authored by Charles Elliott, Virginia Montgomery, Sofie Gowran and Nurangis Sobirkhonova.