PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT? - JANUARY 2021 - Clifford Chance
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PAYMENTS TRENDS
2021: WHAT WILL
THE NEW YEAR MEAN
FOR REGULATION
AND ENFORCEMENT?
JANUARY 2021
PAYMENTS TRENDS 2021: WHAT WILL
THE NEW YEAR MEAN FOR REGULATION
AND ENFORCEMENT?
There has been a renewed focus on the payments sector and its
regulation. COVID-19 and its impact on spending habits and the
Wirecard scandal are two of the contributing factors. But what’s
next? We explore five themes likely to drive regulatory change for
payments, as well as shape the enforcement policies of global
regulators over the next 12 months.
A new roadmap for steps to improve efficiency and in the
longer term through considering the role
cross-border payments global stablecoins and CBDCs could play
2021 will bring renewed international in cross-border payments.
efforts to address challenges and frictions
in cross-border payments, which are still The FSB published its Stage 3
significantly slower, more expensive and Roadmap for cross-border payments in
less transparent than domestic payments. October 2020, building on a CPMI
Correspondent banking (a key channel for Report to the G20 on the building blocks
cross-border payments) continues to of a global roadmap for enhancing cross-
decline, limiting access to cross-border border payments from July 2020.
payments despite the Financial Stability Alongside the Roadmap, the FSB also
Board’s (FSB) work since 2015 to published high-level recommendations
address this issue. for regulation, supervision and oversight
of “global stablecoin” arrangements in
Frictions and challenges facing October 2020.
cross-border payments include:
• fragmented data standards and lack of Also in October 2020, BIS and a group of
interoperability between jurisdictions; several central banks published their
Report on foundational principles and
• practical challenges in meeting global core features of CBDCs. As envisioned
anti money laundering/ counter by the FSB Roadmap, we expect work
terrorist financing and other on these issues to continue during 2021.
regulatory requirements;
• high transaction costs; and At a domestic level, we will see more
economies experimenting with, and
• different operating hours across getting ever closer to wide-scale issuance
time zones. of, CBDCs. In January 2021, it has
already been confirmed that the People’s
While improved efficiency of existing Bank of China’s pilot programme to test
systems can reduce some of these and promote its CBDC (the digital
frictions, the focus is increasingly shifting Renminbi) has been extended to Beijing
towards how new infrastructures such as and other cities, following large-scale
global stablecoins and central bank digital trials in Shenzhen and Suzhou. While
currencies (CBDCs) could offer more China has prohibited private crypto
radical solutions to these deep-seated issuance and trading onshore, legislators
issues. Both public and private sector are amending the law to establish digital
innovation and cooperation, based on Renminbi as legal tender, treading a
internationally agreed standards, will be cautious but steady path to country-wide
key to success. adoption. In the US, a private
organisation, named the Digital Dollar
Recent international publications on Project, published a whitepaper in May
cross-border payments, global 2020 making a case for US lawmakers
stablecoins and CBDCs indicate how and public officials to support a US
policy makers intend to address these CBDC. The US Federal Reserve later
challenges, both through short-term acknowledged that it is actively
2 CLIFFORD CHANCE
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
investigating distributed ledger technologies • a Markets in Cryptoassets Regulation,
and how they might be used to digitise to facilitate their use while mitigating
the dollar. The Dubai Government is also risks for investors and financial stability
exploring its first approved blockchain- (MiCA - see our take here); and
based digital currency, EmCash, which is
• a regulatory framework on digital
intended to be pegged to the value of the
operational resilience (DORA)
UAE dirham.
(see further below).
Diem, or the Facebook-associated
There have also been some significant
stablecoin formerly known as Libra, is
recent developments in relation to crypto
also anticipated to launch in 2021 once it
regulation across the Middle East. In the
has received Swiss regulatory approval.
United Arab Emirates (UAE), the
With several changes since its original
Securities and Commodities Authority has
June 2019 multicurrency-backed incarnation,
recently published new cryptoasset
it is expected initially to launch a single
regulations (which Clifford Chance are
dollar-backed coin alongside other
pleased to have assisted in the drafting
compliance enhancements made to
of), setting out the onshore licensing
satisfy regulatory concerns.
regime for offering cryptoassets, including
participating in initial coin and security
Diem would enter the market at a time
token offerings and providing custody
when US banking regulators appear to be
services and other financial activities in
warming to stablecoins. The US Office of
relation to cryptoassets. The regime
the Comptroller of the Currency “(OCC)”
covers stored value stablecoins and other
issued a 2020 interpretive letter
digital tokens across the payments and
affirming that OCC-regulated banks can
investment space.
provide digital asset custody services to
customers, and a 2021 interpretive
The UAE’s financial free zones, the Abu
letter explicitly allowing the use of
Dhabi Global Market and Dubai
stablecoins to engage in and facilitate
International Financial Centre, have also
payment activities. The OCC also
issued comprehensive updated regulatory
recently announced its first conditional
frameworks governing money services
granting of a national trust bank charter
businesses which will also pick up
to the well-known digital asset custodian,
Financial Action Task Force or FATF
Anchorage Trust Company. The national
standards for virtual currency providers
bank charter will make it easier for
and regulate stablecoins and other digital
Anchorage to partner with banks and
assets relating to payments.
other financial institutions that want to
provide customers with stablecoin
custody services. Antitrust and the
taming of Big Tech
Legislative regimes for stablecoins and Big Tech remains high on global regulators'
other cryptoassets are also being agendas. Major digital technology firms
developed internationally, including in the such as Facebook, Google and Apple
UK, as outlined under an HM Treasury have continued to find themselves under
consultation published in January 2021 increased scrutiny in relation to their data
and in Hong Kong, as outlined in a use and alleged anti-competitive
consultation launched in behaviour generally, including in financial
November 2020. products. For example, the European
Commission announced in June 2020
In September 2020, the European that it had opened an antitrust
Commission published its Digital investigation into Apple Pay for potentially
Finance Package, which builds on its anti-competitive agreements and the abuse
EU Fintech Action Plan published in of a dominant position by limiting access
2018. The Digital Finance Package to its "tap and go" functionality on iPhones
introduced the EU’s Digital Finance for payments in stores and refusing rival
Strategy and a renewed strategy for companies access to Apple Pay.
modern and safe retail payments.
Crucially, it also introduced legislative The next step is the creation of new "Big
proposals for: Tech" regulators and the establishment of
CLIFFORD CHANCE 3
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
dedicated regulatory regimes that will from April 2021 and is to consult on
impact the ability of key tech players to proposals for a new pro-competition
wield market power in rolling out new regime in early 2021.
financial products. The European
Commission recently unveiled its far- Also in the UK, the Payment Systems
reaching proposals for regulation of digital Regulator is currently conducting an
platforms and online intermediaries. The industry-wide consultation with respect to
Digital Markets Act (DMA) will require its September 2020 interim report on the
digital platforms that are designated as supply of card acquiring services and
"gatekeepers" to refrain from a long list of related competition issues.
practices that are considered to limit
competition or otherwise to be unfair. In In the U.S., companies can expect
contrast, the Digital Services Act (DSA) continued scrutiny of Big Tech as well as
focuses on regulating the way that greater focus on the financial sector. In
providers of online intermediary services autumn 2020, the Antitrust Division of the
interact with their customers and users, Department of Justice (DOJ) announced
and their obligations in respect of harmful its intended focus, highlighting rapid
or illegal content, in order to create change occurring in the financial sector
"uniform rules for a safe, predictable and and the potential for anti-competitive
trusted online environment". conduct. In November 2020, the DOJ
In combination, the two pieces of sued to block Visa’s acquisition of Plaid,
proposed legislation will create Europe's a fintech company, and the companies
most interventionist sector-specific abandoned the transaction in early 2021.
regulatory regime in decades, and would Visa’s and Plaid’s decision to abandon
require significant changes to the their transaction will likely encourage
business practices of large digital sector future challenges of US acquisitions by a
players, as well as, potentially, smaller dominant company of an emerging
competitors. While it is likely to take competitor.
18-24 months for final texts to be agreed
with the European Parliament and Council Operational resilience and
of the EU, 2021 will see a flurry of activity personal accountability
and amendments to the proposals. High profile IT failures and the impact of
COVID-19 meant that operational
In the UK, in December 2020, the CMA
resilience (or ensuring the continuity of
issued advice to the UK government on
key business services) was a high priority
the design and implementation of the
for regulators during 2020. This will
UK’s new pro-competition regime for
continue throughout 2021. Growing
digital markets. If implemented, the new
digitisation of customer experiences,
regime will govern the most powerful tech
greater automation of internal processes
firms with strategic market status (SMS)
and increased use of third-party providers
and see the creation of a new Digital
all make firms increasingly susceptible to
Markets Unit (DMU) with powers to set
technology disruption events.
clear rules and impose penalties. The
regime will include a new legally binding
In September 2020, the European
code of conduct tailored to each firm, the
Commission unveiled its proposal for an
introduction of data access and
EU regulatory framework on digital
interoperability requirements, and
operational resilience (DORA – see our
mandatory merger filings for businesses
take here), to better align financial
designated with SMS. The FCA will also
entities’ business strategies with the
be given enforcement and implementation
conduct of internet and communication
powers in regulated sectors. As with the
technology (ICT) risk management and to
DMA and the DSA, while the SMS regime
prevent and mitigate cyber threats,
is expected to apply to only a limited
published as part of the EU’s Digital
number of the most powerful digital firms,
Finance Package.
its overall impact is likely to be much
further reaching. DORA requires firms to have internal
governance and control frameworks that
The government has committed to
ensure an effective and prudent
establishing and resourcing a new DMU
management of all ICT risks.
4 CLIFFORD CHANCE
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
Management bodies will be required to technology and cyber risks, making it
define, approve, oversee and be clear that both are expected to set the
accountable for the implementation of all tone from the top and cultivate a strong
arrangements related to the ICT risk culture of technology risk awareness
management framework. It takes a and management.
“sliding scale” approach to compliance
with critical businesses having greater The TRM Guidelines also require the
compliance obligations than others. 2021 board of directors and senior
will see DORA continue through the EU management to ensure that a Chief
legislative process, with approval from the Information Officer, a Chief Technology
European Parliament and Council of the Officer or Head of Information Technology,
EU still required. and a Chief Information Security Officer or
Head of Information Security, are
We anticipate that domestic regulators
appointed. In parallel, an individual
will also increasingly look to formalise
accountability regime, that will take effect
existing operational resilience guidance
from September 2021, will also require
into specific regulations throughout 2021.
the identification of senior managers with
In the UK, the FCA, the Prudential
core management functions, such as a
Regulation Authority and the Bank of
chief technology officer, who must be fit
England will finalise rules and policy
for their roles.
statements on a new operational
resilience framework for financial services
The MAS has also proposed to introduce
firms, following several consultations
new powers to issue rules on TRM on
which closed last year.
any financial institution in relation to its
systems, irrespective of whether the
The final rules are likely to be
systems support a regulated activity. The
implemented by firms by late 2021/early
MAS views this as necessary as systems
2022 and will require firms to identify their
that do not support regulated activities
important business service and impact
can pose contagion cyber risk to systems
tolerances with a strict liability offence for
that do, due to inter-linkages. To highlight
failing to remain within impact tolerance
the importance of compliance with TRM
levels. Enhanced governance obligations
rules, the MAS has proposed to set the
and a greater emphasis on the
maximum penalty for breaches of the
responsibilities of the current senior
TRM rules at S$1 million.
manager function, will reinforce personal
accountability at board level with clear
Globally, we are also likely to see an
links between oversight responsibilities
increase in enforcement action relating to
and decision making. Firms will need to
operational disruptions. Regulators may
put in place systems and controls to
seek to hold firms accountable for failures
implement a robust communications
in their responses to the challenges
strategy, expand self-assessment testing
resulting from COVID-19, particularly
capacities, assess the systemic materiality
where disruptions arise from cost-cutting
of third party partnerships, and carry
in any economic downturn brought on by
out mapping exercises of resources
the pandemic. In parallel, the same
required to deliver each of the core
technology disruption events (and any
business services.
criticism from regulators,) are likely to
give rise to civil claims – whether for
In Singapore, to address growing
breach of contract, negligence or data
technology and cyber risks for financial
breach litigation.
institutions becoming increasingly reliant
on technology, the MAS recently issued a
Firms will need to act swiftly to factor new
set of revised Technology Risk
regulatory requirements into existing
Management (TRM) Guidelines (TRM
operational resilience frameworks and to
Guidelines), setting out the regulator’s
ensure that any policy changes required
higher expectations in the areas of
for compliance can be implemented in
technology risk governance and security
time, to reduce the chance of suffering a
controls in financial institutions. It provides
significant operational disruption and the
additional guidance on the roles and
risk of associated enforcement action.
responsibilities of the board of directors
and senior management in managing
CLIFFORD CHANCE 5
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
Safeguarding and resiliency surveys (published on 7
January 2021), which found financial
prudential risk
resilience concerns in some members of
management the payments and e-money sector. As
Robust safeguarding arrangements are part of satisfying the FCA that there are
integral to ensuring that funds are robust governance arrangements, firms
returned to customers in the event of an are required to have a wind-down plan to
insolvency of a payment services or an manage their liquidity and resolution risks.
e-money firm. The COVID-19 pandemic Alongside this, the UK is expected to
and the collapse of Wirecard in 2020 introduce a new “special administration
have brought payments firms’ prudential regime” for payment institutions and
risk management and safeguarding e-money issuers to enhance the
arrangements into the spotlight as a key protection for customers if a payment or
supervisory priority for 2021. electronic money institution enters into
insolvency. An HM Treasury consultation
In the UK, the Financial Conduct Authority on the proposed regime published on 3
(FCA) had already been focusing on December 2020 notes that, in six recent
safeguarding rules for payment insolvencies involving payment and
institutions. The FCA carried electronic money institutions, five firms
out a review of non-bank payment service have not returned funds to customers.
providers’ compliance with safeguarding
requirements in early 2019, resulting in a In Singapore, the MAS currently has the
Dear CEO letter that required all power to impose safeguarding
electronic money institutions and requirements on major payment
authorised payment institutions to review institutions in respect of certain payment
their safeguarding arrangements. services, which include merchant
However, the COVID-19 pandemic led acquisition services. In view of the
the FCA to look at this with renewed changing payment token landscape and
focus, quickly introducing new Guidance to allow the regulator to act swiftly in this
in July 2020 to strengthen payment firms’ space when needed, there are also
prudential risk management and legislative proposals to extend 'the MAS'
arrangements for safeguarding customers’ s power to impose user protection
funds in light of the exceptional measures on certain digital payment
circumstances of the pandemic. token service providers, and these
measures may include anti-commingling
We expect that the status of safeguarded measures, ring-fencing measures and
funds will continue to attract attention. maintaining customers’ assets in a
The FCA considers that firms hold prescribed manner.
safeguarded funds on trust for their
customers, even though this is neither In Japan, the Japanese Financial Services
expressly stated in the Second Payment Agency (JFSA) introduced a robust
Services Directive nor in the UK Payment mechanism for safeguarding customer
Services Regulation 2017. The FCA cited money kept by FTSPs when the FTSP
the ruling in Supercapital (in regulatory framework was established in
administration) [2020] EWHC 1685 (Ch) 2010. The June 2020 reform of the
where the judge stated that the Payment Payment Services Act will make the
Services Regulation 2017 creates a current single licence regime more flexible
statutory trust. It is possible that this view by creating three categories of FTSP
may be subject to further challenge in licence and requiring different
subsequent court cases. safeguarding measures to be taken by
FTSPs, depending on the maximum limit
Regulatory scrutiny of the prudential risk of the payment reflecting a principle of
management of payment and electronic regulating based on risk. Other parallel
money institutions is also likely to legislative changes are also designed to
continue during 2021. reduce customer risk in the case of
insolvency of FTSPs. The amended
In the UK, the need for strong risk
regulations will be implemented in
management and governance
spring 2021.
arrangements can be seen from the
results of the FCA’s Covid-19 financial
6 CLIFFORD CHANCE
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
Continued expansion of line with the agreed UK Finance SCA
implementation plan well in advance of
Open Banking and Open
the 14 September 2021 deadline. The
Finance FCA has stated “any firm that fails to
Various jurisdictions have introduced (or comply with the [SCA] requirements …
are in the process of introducing) Open will be subject to full FCA supervisory and
Banking regimes, allowing third-party enforcement action.” Firms are required
payment service providers (TPPs) to to have reached a state of ‘market
initiate payments or access account readiness’ by 31 May 2021 and ‘full ramp
information on behalf of customers. up’ by 13 September 2021, all with
Competition is a key concern and driver minimum customer disruption. UK
for regulators overseeing such initiatives, Finance has stated that issuers will need
with regulators expecting that firms will to start checking randomly if e-commerce
meet their regulatory responsibilities while transactions are SCA compliant, and soft
competing on quality and value. decline them if they are not. This means
that payment service providers,
The UK gateways, e-merchants, and technology
In the UK, initial take-up of Open Banking providers will need to be ready for SCA
has been slow but steady, with over 2 by the end of May 2021, to avoid any
million users at the start of 2021 (doubling unnecessary declines.
in a year). We expect this to continue in
2021, as TPPs launch new products and For broader Open Finance initiatives, the
customers become more confident about FCA proposed “a new rights framework”
sharing data with regulated TPPs. in its December 2019 Call for Input on
Open Finance, consisting of seven
Perhaps more significant is the potential principles for data protection, complaints
expansion of Open Banking to other handling and customer consent tools.
types of accounts and financial products Responses to the call have outlined
under a broader “Open Finance” initiative. concerns that it would be very costly to
For example, the UK Pensions Schemes extend the Open Banking access and
Bill introduced in Spring 2020 includes a consent model to other financial
legislative framework that would enable products, and that the proposed consent
individuals to view all their existing and tracking tools may be better provided
pension pots in a single dashboard by third parties. This indicates that we are
format. The UK has also been considering likely to see further FCA consultation on
other similar initiatives as part of its Smart this topic in 2021.
Data review and the UK government
published its proposed Next steps for Singapore
Smart Data in September 2020. In Singapore, Open Banking has been
However, it will inevitably take time to largely facilitated by the Monetary
develop legislative frameworks for further Authority of Singapore (MAS), which has
initiatives, which will be needed to ensure encouraged banks to adopt application
that third party providers are regulated programming interfaces (APIs) since 2016
where appropriate and to provide clarity with the development of a financial
around important issues such as security, industry API playbook. To promote Open
consent, data use, privacy and ethics. Banking and facilitate the adoption of
open APIs, the MAS has also led several
The rules on TPP access, strong other initiatives, such as the 2018 launch
customer authentication (SCA) and of the API Exchange, an open
secure communication standards under architecture API marketplace and
the recast EU Payment Services Directive sandbox platform.
address some of these concerns in the
context of Open Banking. In December 2020, Singapore also saw
the launch of the Singapore Financial
Following delays in implementation due to Data Exchange (SGFinDex), the world’s
the impact of COVID-19, 2021 will see first public digital infrastructure, jointly
the SCA rules being applied in the UK. developed by the public sector in
The FCA expects firms to be working collaboration with the banking industry.
towards their compliance milestones in The SGFinDex uses a national digital
CLIFFORD CHANCE 7
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
identity and centrally managed online resolve these issues, payment service
consent system to allow individuals to providers will face increased costs arising
access the financial information held from a higher standard of establishing
across different government agencies and and maintaining security measures to
financial institutions. As a public digital access the banking system.
infrastructure, stringent security measures
are in place to safeguard personal data, The Middle East
and the authentication and authorisation Whilst still in its infancy in the Middle East,
process is underpinned by the use of the local regulators are placing an increasing
national digital identity. Participating focus on Open Banking and several
financial institutions continue to be regimes are being developed. The Central
subject to existing personal data Bank of Bahrain (CBB) has taken the lead
protection legislation when participating in in introducing Open Banking regulations
this initiative. In the next phase of in the region, with amendments to the
SGFinDex, it is envisaged that individuals CBB rulebooks made in December 2018.
will be able to access information on their Following the 2018 establishment of a
insurance policies held with insurers and regulatory sandbox, in January 2021 the
their holdings of stocks at the Central Saudi Central Bank (SAMA) announced
Depository of Singapore. the issuance of its new Open Banking
policy. SAMA plans to launch a new Open
In 2021, we expect to see increased Banking regime during the first half
digital innovation and competition of 2022.
between financial services providers in
Singapore arising from the use of Related developments have also taken
SGFinDex, and further government place in the UAE in respect of the
initiatives to support the push towards regulation of electronic payment and
Open Banking. stored value systems such as e-wallets
and mobile payments. 2020 saw an
Japan overhauling of the regulatory framework
In Japan, the Open Banking regime was for digital payments across the UAE. The
introduced from June 2018 to regulate UAE Central Bank replaced its 2017
electronic payment service providers stored value regulations and introduced
(EPSPs), which initiate payments or detailed provisions on licensing and
access bank account information on operating digital payment businesses
behalf of customers. However, broader onshore in the UAE, as well as an
Open Banking principles have been express prohibition on the operation and
reflected for non-bank fund transfer marketing of foreign stored value facilities.
service providers (FTSPs) that offer It has also proposed a further draft
payment services using funds cashed out regulation on retail payment services and
from customers’ bank accounts since card schemes, setting out a
that licensing system was established in comprehensive regime for the regulation
2010. Although these new payment of payment services and seeking to align
services have blossomed with with international standards. The UAE’s
government support, there has been financial free zones, the Abu Dhabi Global
tension with banks. In the wake of a Market and Dubai International Financial
scandal, where customer money was Centre, similarly issued updated and
stolen from bank accounts which were comprehensive regulatory frameworks
breached via FTSP accounts in governing money services businesses, to
September 2020, the level of customer bring their standards broadly in line with
authentication and cyber security the EU Payment Services Directive.
management requested of regulated
EPSPs and FTSPs has become stricter. Whilst these new frameworks bring the
While the Fair Trade Committee of Japan UAE and its financial free zones closer to
noted in an April 2020 report that the international standards in this area, the
current level of fees charged by banks barriers to entry into the UAE market have
could be an impediment to EPSPs or been raised. Whereas firms previously did
FTSPs building sustainable businesses, not require a formal licence, there is now
and encouraged banks and the a comprehensive framework in line with
Japanese Bankers Association to international standards.
8 CLIFFORD CHANCE
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
CONTACTS
Authors
Samantha Ward Laura Douglas Cheryl Jones Meera Ragha
Partner Senior Associate Senior Associate Senior Associate
London London Knowledge Lawyer London
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Lounia Czupper Kimi Liu Yan Li Frédérick Lacroix
Partner Counsel Associate Partner
Brussels Beijing Beijing Paris
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Germany Hong Kong
Hélène Kouyaté Marc Benzler Dr. Christian Hissnauer Rocky Mui
Counsel Partner Senior Associate Partner
Paris Frankfurt Frankfurt Hong Kong
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Italy Japan
Matthew Wan Lucio Bonavitacola Yusuke Abe Hitomi Kurokawa
Associate Partner Partner Senior Associate
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CLIFFORD CHANCE 9
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?
CONTACTS
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Simon Crown Caroline Meinertz Laura Nixon Kate Scott
Partner Partner Senior Associate Partner
London London Knowledge Lawyer London
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10 CLIFFORD CHANCE
PAYMENTS TRENDS 2021: WHAT WILL THE NEW YEAR MEAN FOR REGULATION AND ENFORCEMENT?This publication does not necessarily deal with every important
topic or cover every aspect of the topics with which it deals.
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Bucharest • Casablanca • Delhi • Dubai• Düsseldorf •
Frankfurt • Hong Kong • Istanbul • London • Luxembourg •
Madrid • Milan • Moscow • Munich • Newcastle •
New York • Paris • Perth • Prague • Rome • São Paulo •
Seoul • Shanghai • Singapore • Sydney • Tokyo • Warsaw •
Washington, D.C.
Clifford Chance has a co-operation agreement with Abuhimed
Alsheikh Alhagbani Law Firm in Riyadh.
Clifford Chance has a best friends relationship with Redcliffe
Partners in Ukraine.
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