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        ence across in-person, in-app and mobile commerce chan-  possible while ensuring against anti-competitive behav-
        nels. The UK-based firm leverages open banking among    iors."
        fintechs, third parties and financial institutions to acceler-
        ate payment flows, share data and help service providers   Nicholds has seen European lobbyists attempt to make
        add value to customer relationships. For example, Chip, a   commerce more  secure. This principle is the  basis  for
        Judopay client, created an app that plugs into a consum-  strong customer authentication and a key component
        er's bank account and initiates what Nicholds described as   of PSD2, which was devised to address the need for en-
        "subliminal savings."                                   hanced authentication after fraudsters shifted from card-
                                                                present  to  digital  commerce  following EMV  and  digital
        "Chip  uses algorithms  to analyze expenditure patterns,   commerce migrations, he added.
        save money for users and get them better returns," Nich-
        olds said. "Users grant permission, save money and decide   As part of their efforts to invigorate the market and en-
        what they want to do with it. That's a good example of   courage competition, European regulators are encourag-
        open banking and the kind of client we're supporting."  ing fintechs and other new players to join the payments
                                                                ecosystem. They have also created two new open bank-
        Regulator-led initiatives                               ing categories: the account information service provider
        Nicholds further noted that Europe has a long history of   (AISP) and the payment initiation service provider (PISP).
        regulator-led initiatives, and a number that have come   These regulated entities facilitate secure initiations and
        from the European Commission are working their way      retrievals between open banking providers.
        through to eventually become law. For example, the sec-  End users have a right to understand the specific data that
        ond payment directive (PSD2) came from the European     AISPs and PISPs share and with whom and for how long
        Commission and was passed into law by the European      they share the data. These  requirements fall under Eu-
        Parliament.                                             rope's General Data Protection Regulation (GDPR), which
                                                                became law in May 2018.
        "It sometimes takes a while to pass legislation," Nicholds   Changing currents, currencies
        said. "Some countries are quite speedy; others take more
        time. The European focus has centered on the overall com-  As he reflected on global efforts to improve payment
        merce ecosystem and market, trying to make it as open as   flows, Nicholds suggested that the current system is not
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