General counsel | Payment Systems Regulator

Alex Olive
General counsel | Payment Systems Regulator
What are the key projects you have been involved in over the past twelve months?
I have provided stability, direction and resilience during one of the most testing periods in the PSR’s ten-year history.
I have faced several parallel and novel challenges in the last year:
· Issuing final reports against Visa and Mastercard on significant market power, high fees and opaque pricing, and leading the legal advice behind sectoral and international firsts in remedies.
· Related judicial reviews by Visa, Mastercard and Revolut, challenging the PSR’s legal power to regulate these fees.
· Government announcement of plans to merge the PSR into the FCA.
· Leading the organisation and my department through structural transition two years before the legal effect of the merger.
· Maintaining pace and legal rigour across competition enforcement, fraud reimbursement, regulatory enforcement, infrastructure analysis, access regime design and the Treasury’s National Payments Vision.
· I have also taken on a substantial FCA legal and SLT portfolio alongside my GC role, adding breadth from a 5,000-strong organisation.
Throughout, I have sought to lead with authority, strategic clarity and provide broad collegiate support well beyond legal advice, while staying focused on operational delivery and our people.
Four themes best define my impact and contribution:
1. Leading transition
2. Shaping future regulation
3. Defending the PSR
4. Public strategic thought-leadership
Please provide a brief description of any internal transformation/development projects within your legal team over the last twelve months, such as AI usage, new legal panels, expansion/restructuring of legal team, DE&I initiatives etc.
· In many ways my answer above highlights the structural team transformation I have been leading and the significant legal reform affecting my team. To do this successfully, and kindly, l embedded strong support mechanisms for my team. I arranged additional systems to discuss the emerging developments, feedback concerns to the executive, focus on and discussion on the most pressing issues and promote transparency.
· I secured mental health support for the team, facilitated coaching, brought in key FCA speakers to help reduce anxiety, and held “open door” sessions. I carefully managed sick leave and flexible working needs during an emotionally demanding period.
· Result: I averted flight risk, the team continued to deliver high quality work, on time and budget. Staff survey scores were unanimously positive on Management Support, outperforming all organisational comparators.
What are the most important attributes of the modern GC and what advice would you give to those aspiring to be an in-house lawyer?
First, I feel strongly that if a legal piece of work doesn’t factor in the commercial objectives of the organisation, the wider policial and economic landscape, and partner with the client in doing so – then really, it isn’t advice at all. It is not good enough to say “there is a risk”. I ask my team to convey a strong sense of degree, consequences, workarounds, options and ‘what if’ scenario planning.
Second, a “modern” GC might be drawing from a far wider set of diverse influences, including visual communication/arts, group and psychological theory, economics and financial modelling, and operational excellence models across sectors.
Third, it may be a cliché but I have seen too many lawyers still hide behind words – something GC’s must guard against to maintain business-level trust and rapport. I have a few recurring catch phrases to help maintain focus on this (which is a bit of running joke):
– “Can we word Hoover please?”
– “What’s the single picture version?”
– “A perfect sentence has no more than nine words [there are nine here…]”
– “Why should they care?”
I would say this for any lawyer but particularly for the inhouse team, the preparation should start with:
– What do they need to know
– What do they need to understand as a decision maker
– How can I make it easy and retainable
– How do I sustainably minimise costs and time
– How do I upcycle this for the future
These ideas are not new, but serious attention to strategic judgment and communication/teamwork is what differentiates a trusted business advisor from AI.
How do you help drive strong governance and ethical decision-making across your organisation?
I keenly understand how work pressures can make governance seem like a hurdle to be avoided, box to be ticked, or an exercise in persuasion/approval rather than a valuable exercise in itself. Ineffective governance can create unintended staff incentives, which can be harmful. I spent two years iteratively reforming the PSR’s governance, and shift the working level culture, to address these risks and improve the dialogue between different levels of hierarchy/formality. It is about focusing on the client and testing whether the frameworks – and culture it creates – are supporting the objectives.
I seek to convey why the review should be meaningful, not a rubber stamp exercise, and that means the decision-makers should be given the information they need to take a fully informed and reasoned view. That is harder work of
course, when page counts and attentional capacity is limited. But it is also more satisfying for all.
I seek to highlight that difference of opinion, perspective and skills is a huge gift to robust decision-making. I would worry about signs of group think or passive acquiescence, in terms of lack of joint accountability. It is more intellectually satisfying for the team if they are shown respect, are given the chance to explain themselves, and can explore some of the nuances / judgments with the SLT. As a lawyer but also as a GC who is part of the Exec and sits on the Board, I am keen that questions are asked, but even more importantly, that differences of view are explored through active curiosity and openness to discussion.
At the end of the day, strong ethical judgment and effective governance should be very explicitly designed to support successful outcomes – whether regulatory or commercial. That can often mean looking at a wider set of factors, including reputation and trust, or a longer timeline, and always being clear on “how confident would be I be in explaining to an informed outsider, why is this the right thing to do”.
I call it the blush test. It can be very powerful.
Beyond your legal role, is there a cause or initiative you are especially passionate about?
I have been active in the DEI and mental health space for over a decade. I believe it is an absolutely vital element of the profession and for all organisations I have worked in, to drive personal and organisational performance and enable the sector to thrive.
I have designed embedded mental health frameworks for two different regulators and have taken on this role for the FCA’s Legal Division. I am a qualified mental health first aider, an active member of the FCA’s DEI Board. I am also a vocal advocate for mental health in the legal community including speaking at the Lawyer GC Summit, Women In Payments and Legal Tech Talk.
Quite outside my day job, I am also a Board Advisor to the Mindful Business Charter, a charity that focuses on promoting healthy working practices in the legal profession and similar sectors. I collaborate on and peer review their strategy, increase their outreach and offer perspectives on the mental health risks in the regulatory context.
I am also longstanding mentor in the Women@Competition Mentoring scheme, an Awards Panel Judge for Women in Payments EMEA and participate in a mentor scheme for Women in Open Banking.
I find these roles extremely rewarding, and they give me the opportunity to connect with new people and help shape the discussion and awareness of such important issues – as well as learn and develop as part of that sectoral wide engagement.