A client called and asked me: “WTF is internal control, how is it different from compliance and how do I document that my internal control is effective quickly because I have a call with auditors in 1 hour…” Well, Internal Controls are a sum of all your compliance, risk, and Read more…
Today, I wanted to talk (again 😬) about the “Travel Rule” for blockchain transfers and what might be the first simplified implementation of it for a FInTech startup that’s getting very confused by various complex solution providers and consortia offerings. 1. Scope – What is the “Travel Rule”? FATF issued Read more…
I observed recently how old-fashioned tabular or matrix-based risk assessments were questioned and challenged by regulators and also by white-label service providers during due diligence reviews. The challenge looked like a series of questions or (in some cases remarks that looked quite biased and even rude) from the reviewers: Your Read more…
In the last months, a few of my FinTech clients have asked me to review their application forms for bank account opening. Here are examples of SUPER IMPORTANT questions (that look very innocent and almost boring) where I felt the original answers were completely misleading, out of context, and would Read more…
Even if you are in the early stages of starting a FinTech company, you should be thinking about how you are going to categorize and segment your customers. These tags or categories, later on, will lay the foundation of your ongoing monitoring program. Here are a few tags/categories/attributes I recommend: Natural persons Read more…
We were recently talking and giggling with peers and colleagues about how Bitcoin Suisse ⛑ was trying to solve their operational issues by increasing the number of minimal required customer deposits and how many banks are now introducing KYC and onboarding fees 💰 for all new clients. You know why Read more…
Most compliance officers would agree that onboarding and reviewing corporate customers is one of the most painful and annoying KYC tasks ever. It takes forever, it’s confusing, and everyone involved (customers, UBOs, compliance officers, and relationship managers) hates every step of the process. BUT WHY? Why cannot we all simplify Read more…
Someone recently asked me if they could outsource all their KYC and onboarding tasks for their new business idea to me (or someone else I could recommend) and I did not think it was such a great idea. I strongly feel that FinTech or any other customer-facing startups should keep Read more…
On August 26th 2019, FINMA issued additional guidelines to clarify Swiss position with respect to AML/KYC requirements as they relate to blockchain-based transactions. As a reminder – this comes as an aftermath following FATF requirement to mandate so called “travel rule” to be applicable for blockchain transactions, which essentially Read more…
When you are a FinTech startup just coming up with a beta product, the minimum of the minimum customer tags and categories you need are: Legal entities vs natural persons High risk vs standard risk customers As you grow, have more customers and add complexity, you can build on it Read more…