Clients and assignments

Regulatory consulting
Over the years I have delivered services such as setting up programmes, projects and developing business and regulatory strategies. I have done so in varying roles as projectmanager, trainer, coach, bank supervisor, policy-advisor, head of a department of professionals and compliance manager (see my LinkedIn-profile for further details).

I have advised clients such as: the Dutch Bankers’ association, Paypal, the Dutch central bank, Intersolve, the Electronic Money Association, The Dutch payment association, and both a range of smaller financial startups, a crypto-company and larger corporates.

I assist my clients in finding pragmatic solutions to the business development and regulatory challenges that they face. In the delivery of services I join existing teams or work together with partners such as KPMG, van Doorne, Finnius and Payments Advisory Group and Connective Payments.


Business development and regulatory strategy
I assist clients with the further development of their business strategy and the legal rules that apply, depending on the business-setup. This comes down to designing or running the regulatory compliance framework for issuers of new currencies, loyalty systems, e-money or for blockchain companies. Another example is the strategic change-over of a private label payment card to a PSD2-compliant payment instrument in the context of an EU corporate that was resdesigning its back office systems.

License application/registration/notification
I assist companies in the process of license/registration application or filing of notifications for exemptions under the law. While this is mostly a behind-the-screens activity, in my last assignment it was necessary to litigate after having received approval to enter the market, due to a difference of opinion on the interpretation of the law. This is of course process that requires maintaining a good and open dialogue while agreeing to disagree with the supervisor. Over time I have also come to appreciate the use of instruments such as the formal request for information (WOB/WOO-verzoek) and enforcement requests, to ensure better insight and a fair treatment of the market by supervisors.

Workshops and courses
I have held workshops on request of a number of organisation to further discuss future developments in payments, supervision and blockchain. In one case the workshop was geared to sharing the payments-industry basics with an entrepreneur, considering investments in new-currency based startups. Another example is a one-day course on blockchain and its impact, that I developed for a financial institution. See also the page on my blockchain involvement and activities.

Conferences en events
I have cooperated with local publishers and organisations on a number of events that have to do with payments. I regularly appear on media and act as a trainer, key-note speaker, chairman of events. See for more information this page.

I work as an compliance officer or interim-compliance manager for clients that wish to evaluate their compliance with regulatory rules. I assist with the interactions and dialogue with the supervisor and lay out alternative scenario’s in order to find a pragmatic but well organised and documented way forward. In some cases this incudes choosing formal enforcement request procedures or even urgent law suits to ensure that the company and supervisor come to terms as to the interpretation of legal requirements and/or the applicaiton of cost-regimes for supervision.

Position papers
I assist companies and trade bodies with the analysis of regulatory developments in Europe and the drafting of position papers. The past years I have contributed to both national and European legislative consultations in the area of payments, security of payments and supervisory regimes. My most recent work relates to the VBNL, the work for Verenigde Bitcoin Bedrijven Nederland, where I assisted in drafting draft position papers, letters and provided input to law suits with respect to the cost of supervision.

Impact assessments and business redesign
New regulations require an assessment of their impact on the business and the business model. I perform these assessments with a view to maintaining flexible and compliant in the future. An example has to do with analysing the impact of financial legislation on the instant crediting of cash inflows.

Lobbying and position papers
The Electronic Money Association in London required my assistance on the areas of security of mobile payments, bitcoin/blockchain, the impact of the Payments Account Directive and some internal work for the organisation of their website/intranet. In this case I took up the role of a temporary and part-time staff member. In the last couple of years I have contributed to the work of the Verenigde Betaalinstellingen Nederland, the association of Dutch Bitcoin Companies in the Netherlands.

For a department of payment-professionals I acted as the interim-manager for half a year, to cover for a period of illness of a line manager. I’ve also held an interim-position as compliance manager for a one-year period at a Dutch electronic money institution and as compliance advisor for 3 years at the oldest bitcoin firm in the Netherlands. In this periode I also acted as the designated MLRO-offficer.

Return to consultancy