There is a wonderful compliance case study hidden inside the FCA’s £3.5 million fine against Coinbase’s UK payments entity. Not because Coinbase broke the law. They clearly did. This story is a magnificent demonstration of what happens when very intelligent people spend enormous amounts of time and money managing a Read more…
There is a side of compliance that rarely gets taught. It is not just about identifying problems. It is about knowing what to do once you see them. Over the past year, I have been hands-on in about a dozen compliance projects, interviewed more than 50 senior compliance leaders and Read more…
When it comes to FinTech licensing, about 50% of review time is spent by the regulators on “fit and proper” assessment and the overall team organization. Furthermore, many regulators will not even commence any policy or financial plans review before they are comfortable with the team structure. Obviously, team composition, Read more…
I am really happy and excited when my network contacts or blog readers or even random FinTech enthusiasts reach out to me and ask their questions. Please keep them coming – this is how I learn about your most common concerns and challenges and can produce better and more relevant Read more…
Today, I wanted to tell you about one fun fact… Recently licensed FinTech companies are typically super excited, they prepare their PR statements and go on a roadshow to announce their license approval to the world. In 100% of the cases I know of, they say something inaccurate or politically Read more…
Today, I wanted to share with you some of the most common scenarios where FinTech license applications get stuck. 😉 Curious? – Read on! 👓 Not knowing how to respond to broad open-ended questions such as “describe the flow of data within your organization”, “describe how do you detect risks related to Read more…
Let’s talk about the relatively new phenomena of licensing pre-applications and how to make them go quickly. ⏩ License pre-application phases are introduced by many (but not all) regulators as a formal step before you can apply for any license or authorization. Regulators don’t want companies to just send them an Read more…
I’d like to compare the pros and cons of buying a regulated entity versus applying for your own license. The main advantage of buying a licensed company versus creating one and applying for the license is that you can continue to operate an existing business. With the new entity, you Read more…
Average payments or e-money license or money services or a VASP regulatory approval takes about 8-12-18 months. And actually only 10-15% of companies who apply get there, the vast majority of the applicants either abandon their applications, run out of money or get an unfavorable prognosis from the regulators and Read more…
After years of doing FinTech compliance consulting, I am now in the enviable position of being able to be picky about my clients. I have declined to join projects – and left some of my (former) ones – over a dozen times over the last 24 months. These decisions have very Read more…