The Finance Shelf

FinTech and Regulatory Framework: A Comparative Study Between United States of America and United Kingdom (PUBLIC ADMINISTRATION AND LAW REVIEW)

Research paperPUBLIC ADMINISTRATION AND LAW REVIEWSeptember 202622 pages33 min readAsif Zaheer Shaikh, Muhammad Shaheer Shaikh, Humayoon ZaheerOriginal source
Key number
US$210 billion
Total global FinTech investment peak cited (KPMG) p.21
What changed
31 March 2025
UK operational resilience transition deadline p.15

Summary

  • In 1967, Barclays introduced an early automated teller machine (ATM) in the United Kingdom, establishing 24/7 self-service consumer banking access.p.10
  • The U.S. post-crisis financial oversight architecture was fundamentally reformed following the enactment of the Dodd-Frank Act in 2010, which created the CFPB.p.12
  • The UK Financial Conduct Authority launched its Innovation Hub in 2014 to assist innovative firms in navigating regulatory requirements.p.15
  • The FCA opened its pioneered regulatory sandbox to eligible applicants in 2016, providing a controlled environment for live product testing.p.15
  • The Federal Reserve launched its 24/7 instant payment service, FedNow, in 2023 to expand United States payment infrastructure.p.13
  • In the UK operational resilience framework, participating firms were expected to remain within impact tolerances for critical services by 31 March 2025.p.15

Key insights

  1. The United States relies on a multi-agency federal and state structure that provides specialized oversight but creates regulatory fragmentation.p.1
  2. The United Kingdom applies a comparatively centralized governance model led by the FCA and PRA, offering streamlined pathways for supervisory dialogue.p.1
  3. Regulatory sandboxes and innovation hubs enable controlled testing while gathering information to help regulators adapt rules to evolving risks.p.6
  4. Technology acceptance frameworks show that user trust and facilitating conditions are critical determinants of digital financial service adoption.p.4
  5. The United States enacted the GENIUS Act in 2025 to create a federal regulatory framework specifically governing payment stablecoins and reserve standards.p.13
  6. Under the UK Open Banking mandate implemented in 2018, major banks were required to grant authorized third parties API access to customer financial data.p.15
  7. FinTech governance faces an ongoing policy trade-off between fostering competitive digital innovation and maintaining consumer safeguards and systemic stability.p.17

Topics and entities

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