FinTech Startup Compliance Pro Certification

Why I created the FinTech Startup Compliance Pro Certification?

Compliance professional education is broken and does not prepare us to deal with the realities of the fast-paced resources-constrained startup businesses facing multiple regulatory and economic uncertainties. Every single compliance professional working in FinTech and crypto can list at least a dozen of situations that happened just last week, where the compliance recommendation on what needs to be done was not clear or obvious. 

It gets worse... Even when compliance and regulatory experts (as well as founders and board members) know exactly what they should be doing in theory, they don't do it. 

Here are just a few examples: both, compliance leaders and founders overthink and delay decisions that "feel hard", they overspend on compliance tools, micromanage their teams, second guess past decisions,  play devil's advocates and overprepare and overthink what may happen.

As a result, they often don’t do what they know they “should be” doing – delegating, simplifying, accepting reasonable levels of risks, and not trying to solve future problems at the expense of complicating current problems.

Absolutely, a part of the hesitation and efficiencies can be explained by the lack of experience or uniqueness of the business model, but in the vast majority of cases, more conservative and more expensive options are selected simply due to the lack of confidence and lack of clarity. 

Many of my clients and students tell me that they are afraid that their preferred solution or preferred strategy won’t pass the test of time and may lead to some unintended consequences. 

The problem of "I don't know what I don't know" is not new. Obviously,  the path of slowly gaining confidence by gaining experience takes years, and  may keep you in the comfort zone for a very long time. Objectively, you will be underutilizing your own leadership skills and overspending your company’s money during this time, which is not a very sustainable strategy.

Which is why I asked myself – how can I help my clients and students gain this sense of confidence faster by creating accelerated learnings and accelerated challenges in a sandbox environment?

BINGO!

The FinTech Startup Compliance Pro Certification is designed to OVERCOME THE MAIN REASON why compliance and regulatory professionals don't do what they KNOW they should be doing: they don’t choose optimal business solutions or their preferred strategy because they fear it won’t work 🙁  

So, in addition to teaching compliance and regulations and telling my clients what to do and giving them all necessary templates and resources, I have decided to enhance my signature Self-Starter Program by adding a series of interactive assessments and assignments encompassing all key areas of FinTech compliance, where people tend to overthink or get stuck.

I will be the “bad cop”, difficult auditor, rigid regulator, challenging your approach, but also giving you the tools, ideas and arguments how you can win your case and defend your strategy.

I have been a very vocal opponent of CAMS certification and other institutional trainings for many years. I offered my arguments of how they keep compliance experts stuck and underpaid… 

How the FinTech Startup Compliance Pro Certification approach is different from the traditional compliance courses:

Have skin in the game

OLD WAY: Traditional compliance assigns responsibility to the “tone at the top”, removes responsibility for risk management from compliance stating that “business must own their risks” and describes compliance as an advisor, providing feedback and reporting to the senior management. According to this outdated theory, compliance can only be blamed or found guilty if it did not detect some risks or irregularities and/or did not warn or escalate the issues accordingly. Every single time we read about the fact that some high-profile bank had been fined by their regulator for money-laundering breaches or excessive risk-taking, you will see and hear the same story: compliance and risk identified and escalated the issues or potential risks well in advance and repeatedly, the problem was discussed by the board and various committees and then the was a collective decision to go ahead and do (or allow) the activities that happened. Assigning responsibilities to the top and isolating compliance from business and risk-taking decisions does not produce better compliance or better business outcomes.

New WAY: Our approach is focused on making sure that compliance is the ultimate decision-maker. Compliance leaders want to be included, respected, and appreciated for their insights. But this respect cannot be earned if you are not responsible for anything and have no skin in the game. We teach you how to take risks that you are comfortable with and can defend in front of others. 

Success in compliance has no correlation with resources or time available

OLD WAY: Traditional compliance scholars will tell you that the key to compliance success is to make sure compliance gets adequate resources and more senior management attention. What’s wrong with this? Ask any CEO and/or CFO of any financial institution or even a smaller FinTech (off the record, obviously) and they will tell you how they spend a disproportionate amount of time in compliance-related, audits, risk reviews, and similar meetings, where they learn nothing new, decide very little and don’t see things improving. The more resources traditional companies and scale-up FinTechs invest into compliance, the more new issues they identify that need to be solved. The biggest compliance fines are very often paid by the biggest banks.

NEY WAY. We teach you and will ask you to prepare an assignment on how to do the right things at the right time and how to take pragmatic risks without compromising compliance objectives.

Manage compliance as a revenue-generating function, not a cost center

OLD WAY. Traditional compliance scholars view compliance as a cost function, that needs to receive an appropriate budget. Traditional compliance certification training won’t teach you modern project management skills, or project prioritization skills, or pragmatic risk-taking skills. They teach you “how to be on the safe side”, “protect your back” skills, and “better safe than sorry” strategies. When you don’t get things done and cannot prioritize available resources and won’t help your company achieve its strategic goals, objectively speaking, you add zero value to the company.

NEW WAY. We will teach you how and will ask you to prepare an ROI assessment for your compliance budget, and by the end of the program, you will be ready to act like a business-like CCO.


WHAT IS INCLUDED INTO THE CERTIFICATION

Below is the Certification-specific curriculum:

1. Goal-setting. Our first group call is a workshop dedicated to determining specific deliverables or professional results each participant decides to set for themselves or their function.

2. Manage regulatory change workshop is dedicated to developing the skills needed to prepare and manage any regulatory change. We will use the example of MICA Regulation implementation, and in particular - on building a new MICA-compliance framework for token listing and token assessment to get compliant with MICA disclosure requirements.

3. Preparing compliance ROI and communicating with senior management. We will have a special training where the participants will have to analyze key components of the compliance costs prepare a project analysis for a new compliance initiative using ROI method. This workshop also provides you with a framework to address disagreements between compliance and business using NLP framework.

4. Developing Annual Compliance Plan training covers the following areas:

  • Organizational structure
  • Hiring and firing principles
  • Setting revenue-generating objectives
  • Making ROI-based resource estimates
  • Defining KPIs for all key compliance areas: new products, AML, risk management, reporting, outsourcing, funds safeguarding, and governance.

5. Behaviors that keep us stuck and conflict resolution. Everyone who was unable to take an agreed-upon action, feels “behind” or otherwise is unhappy with their progress, will have to assess what is preventing them from taking a different action and will get coaching and feedback on how to make the changes they desire to see. This training also covers communication strategies helping you solve intra-departmental conflicts using the NLP methodology.

Final Assignment – where can you take more risks? The participants will have to identify, prepare, and justify a case study about where their function or company should take more risks. 

All content of the FinTech Compliance Self-Starter Package (including the certification module and access to certification-specific workshops and content) is instantly available to all participants. 

You will also get access to the following templates (updated for 2024) to set up your FinTech compliance documentation:

  • AML, KYC, PEPs, sanctions policies and SOPs, onboarding flow setup guide (including policies, tools review, and guidance on admin and case management setup)
  • Privacy and GDPR module, including privacy policy, GDPR compliance policy, binding corporate rules, and standard contractual closes or Data Transfer Appendix template (to be included in all your contracts with vendors and payments partners where data transfer is involved)
  • Outsourcing framework setup, including outsourcing policy template and outsourcing assessment checklist
  • Consumer and Investor Protection, including Customer Protection and Complaints Handling Policy, Investor Protection Policy, and Customer Funds Safeguarding Procedure (for fiat and crypto services)
  • Information Security, including InfoSec policy, incident management, and business continuity policy
  • Blockchain-specific regulations, including Blockchain Operational compliance policy 
  • Corporate Governance and Board of Directors set up, Code of Conduct, Segregation of Duties guidance, Anti-Bribery and Corruption procedure, and other relevant templates (e.g. gift policy, HR screening, etc.)
  • Business-wide risk assessment and product risk assessment (with dedicated sections for AML, Product, VASPs, General Risks, Financial Risks, Startup Risks, and Regulatory Risks)
  • Risk Management, Assessment, and Fraud Prevention, including relevant Risk Management policy and Risk Assessment and Risk Assessment methodology templates
  • Conflict of Interests and Insider Trading Policy
  • Terms of Service, Affiliation and Loyalty Programs structuring (including sample language for loyalty points or reward programs, beta testing provisions, and affiliation program templates)
  • Inter-Company Agreements and SLAs
  • Detailed and comprehensive Annual Compliance Plan and sample Internal Audit Plan. Compliance Assurance Framework (roles of FLOD, SLOD, audit)
  • FinTech Licensing - including License Application Template, financial projections template, business plan template, FinTech licensing roadmap, first regulatory inquiry template
  • Token listing and token assessment criteria (for cryptocurrency exchanges or wallets).
  • FATCA and CRS compliance policy

Implementation workshops included:

  • Opening bank accounts 
  • Managing your own FinTech licensing 
  • Structuring White-Label solutions
  • Choosing between the white-label and your own licensing
  • FATCA/CRS implementation workshop
  • Onboarding and risk-rating for corporate customers 
  • Performing due diligence on your future financial partners (to avoid the risk of over-reliance on Wirecard, FTX or Railsbank)
  • Creating your FinTech Privacy Policy and managing your GDPR compliance  
  • End-to-end Blockchain Compliance (Including a special training on Apple and Google Appstore Guidelines compliance)
  • Preparing for and managing external audits 
  • Standardizing and simplifying you annual compliance reporting
  • Complying with Apple and Google Appstore Guidelines
  • Documenting your Outsourcing 

... AND, BECAUSE I ACTUALLY GIVE A FAQ!

Below you will find some of the most common questions people have asked me before deciding to sign up for the FinTech Startup Compliance Pro Certification.
What should I tell my company so that they cover the costs of the certification?

Compliance Certification is not just a training and certification program, it also grants you access to TONS of VALUABLE TOOLS AND TEMPLATES (called FinTech Self-Starter Package).

Investing in the Self-Starter Package + the Certification is a smart investment with ROI of over 3000%.

Download this template resources request and submit it to your boss for approval.

Your company can delay this important investment decision, as some short-term thinkers do, but a few months later, they usually find themselves having to pay much more for audit findings remediation, urgent consultancy, and other unnecessary and entirely avoidable costs.

What can this Certification do for me? How does it help?

Most clients and students who work with me often find themselves at the turning point, where they want different results and faster progress. For example, you may be unsatisfied with your role in the company, your work-life balance, your level of confidence, your income, your team performance, or how your management perceives your input, and you already know you need to do things differently. Most likely, you don’t need to learn anything about regulations, you actually need to stop procrastinating and start acting – negotiate differently, delegate more, take on more smart risks, secure and spend resources differently, and maybe change jobs or bosses or teams… Fintech Startup Compliance Pro certification is not about learning, it is about setting new goals and then doing new things to achieve them while receiving feedback and guidance at the same time.

This program will elevate your competence and confidence to the next level where you feel ready not only to set and manage a superb compliance program within your FinTech startup, but will have a framework for making pragmatic risk-based decisions.

What is the time commitment? How the program is scheduled?

The Certification Schedule for 2024

3 cohorts are currently planned for 2024:

  • Starting on January 15 and graduating by April 15.
  • Starting on April 15 and graduating by August 15.
  • Starting on September 16 and graduating by December 16.

If you would like to obtain the official certification as a Certified Startup FinTech Compliance Pro, you will be asked to complete a number of mandatory trainings and prepare your case study project, which will be assessed and graded. 

The time commitment for certification completion is about 30 hours.

Eligibility requirements for successful completion of the Certification

  • You must attend live or watch the recordings of 10 out of 12 workshops (if you joined any of the live workshops in the last 12 months, it would count as a completed workshop, otherwise you must watch the recorded training and follow the workbook).
  • You must attend live or view the recordings of all 5 specific workshops that are mandatory for the certification (see the schedule and joining instructions below).
  • You must successfully complete the final assignment.

Grading Criteria for the Final Assignment

Your final assessment should describe a new initiative, new project, new opportunity, or new methodology ideally related to the goal that you identified during our first session. It should be approximately 4-6 pages long and must be a narrative/analysis (as opposed to high-level bullet points).

After Certification

Your access to the FinTech Compliance Self-Starter content and Certification training is not time-limited. It means that you will automatically get access to new recordings and document updates and new versions of templates and trainings. You are welcome to view any future recordings of any updated version of the training or workshops and download any future templates that will be added to the program at any time. No additional payments are required.

What are the possible examples of situations that can be my personal risk-taking goal and my case study during the Certification?

Here are possible examples:

  • You are confident with compliance and regulations, but not entirely satisfied with yourself as a manager. Perhaps you don't feel confident with budget negotiations, securing engineering resources, managing stakeholder expectations, estimating timelines, delegating, or improving your team's performance.
  • You feel uncomfortable making final decisions about compliance or risks and fully assuming responsibility for possible consequences. To compensate for this lack of certainty, you seek additional senior management approvals, call for additional meetings and group decisions, and you sense that your CEO or senior management is becoming more and more resentful and dissatisfied with your approach.
  • You want to grow within your company or apply for the next level role, and you don't feel 100% ready. Maybe, you know a few aspects of compliance very well but never had exposure to some other areas, and you'd like to build a well-rounded profile compliance profile. Perhaps you have overstayed in the deputy/interim MLRO/Head of Compliance/CCO role and you don't see how you can move from the deputy to the actual role.
  • You have bad organizational habits and you don't know how to stop them: over-preparing for meetings and presentations, overthinking and holding back your opinion or your ideas, not delegating enough, accepting poor performance or unprofessional behavior of others that result in you having to work more and longer, or making professional compromises that you regret.
  • You like FinTech and you like compliance, but you don't like your current role. Maybe your job feels safe and boring, maybe it's too stressful and unrewarding, maybe you love your team, but don't see eye-to-eye with your senior management.

What if my company (my boss, my auditors…) are too conservative and I will not be able to apply common sense compliance?

Frankly, it is not useful to continue to be focused on other people's expectations and external circumstances. If you operate based on your external limitations, you will likely repeat your circumstances. This is why the certification will start with your own goal setting and defining what you would like to change. There are millions of options for you to achieve what you want that you have not tried yet, even if your boss, your company, your board, or your auditors (or all of them) are reluctant to change:

  • Present different arguments
  • Negotiate a pilot or trial project
  • Gather new data
  • Assemble a different team
  • Do things your way without telling anyone
  • Form new alliances within the company
  • Change the company and move on
  • Change your goal…

You are never really stuck, you just don’t like the options in front of you, and you are skeptical they won’t work. But it is never true that you actually tried everything and nothing works anymore.

I am not a compliance person. I am actually the CEO/COO and I make ultimate compliance decisions for our company because we are a small team and we don't have full time compliance person yet. Does it make sense for me to join or do I absolutely need the compliance background?

There are two main reasons why a business person with a limited compliance background can benefit from completing the FinTech Startup Compliance Pro Certification:

  • You will learn the basics of how to make compliance decisions and trade-offs, and it will give you the confidence in the future to be a leader for your compliance team. If you ignore or disagree with their recommendations, you will know what you are ignoring and why.
  • You can keep the certification as your tramp card every time someone tells you that "you are not an expert in compliance". It's not about the paper, actually, it is about the fact that you took the time to dive deeper into the topic and to practice and master the skills any compliance leader needs.

So, tell me – are you still in?

At this point, you may be asking yourself if you should continue figuring things out on your own or not. This is actually the wrong question to ask because every successful leader will tell you that they got where they are because they had mentors, external advisers, and support from more experienced people.

So, the more powerful question you should be asking is WHO can support you and WHERE you can find help and continued guidance. And as you already know, if you choose nothing... then nothing changes. You can obviously keep the status quo blindly pouring more time and money into compliance without much hope of creating different results or reversing existing inefficiencies... But why would you put yourself into this position, pursuing a broken strategy, draining your resources, and creating more and more organizational conflicts?

So –

  • Are you going to continue to be a person who plays a victim, complaining about confusing compliance requirements, unreasonable auditors, or some other uncertain circumstances or will you take responsibility for being a leader and problem solver?
  • Are you a person who sees obstacles or opportunities? More specifically, will you be a forward-looking visionary leader who sees how agile compliance can be a massive competitive advantage for your business?
  • Are you someone who waits for the perfect time or an action taker who knows when enough excuses are enough excuses, and it’s time to move ahead even when you don’t have all the answers?

Well, if you are a smart action-taker and ready to commit, simply click this link and I will be waiting for you on the inside! 

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