Compliance in 2021 is Not About Providing Requirements Or Feedback, It Must Be Implementation Function (Or It’s Irrelevant)
I don’t believe that information is power in 2021, especially not in FinTech. Information about how one should run a FinTech business is everywhere and you can get it for free. More information does not empower anyone, more likely than not – it just creates overwhelm.
Which is why, in my opinion, many functions and professions that used to view themselves as just information providers or “decision enablers” (think about traditional compliance, risk, internal control, many areas of finance, such as accounting or reporting) are having hard times justifying not just their cost, but also their long-term organizational value.
Think about compliance and regulations: most founders and FinTech business leaders are intelligent and curious people, they have access to Google, LinkedIn, and Twitter and they (more or less) know what the legal requirements are.
If compliance’s only value and only role is to set the requirements or review things and find deficiencies (and not be a part of any implementations or solutions), you could give this job to a fairly junior person.
Here is one example: When I talk to my founders and CEO clients about “Travel Rule” – they already know what it is and what FATF concluded, and what Christine Lagarde said and what FinCen proposed and what Circle and Coinbase have published… They don’t need more education from me. They expect me to tell them something they don’t yet know – what are the implementation options, pros and cons of various implementation strategies for their business and their clients.
Founders want to know why SEC went after Telegram and Ripple and was so forgiving when it came to Block.one and what does it mean for their business model (I have a theory 😉).
Another problem with any function that sees themselves as “just an information provider” is the forever growing number of internal conflicts, when (for example) everybody else is complaining about compliance requirements being too heavy and decisions being too slow.
It all happens when different functions have conflicting incentives and goals, which ultimately comes down to the same story of compliance reducing their roles to articulating requirements or granting permissions without being a part of coming up with solutions and testing strategies and calibrating the company’s approach to risks and uncertainties. Short-term narrow-thinking compliance professionals may justify it by arguing their “second line of defense” role, which actually has nothing to do with removing your function from implementation responsibilities.
If you work in FinTech and want to reduce the amount of never-ending time-consuming unproductive debates around compliance requirements and their implementation burden, I’d like to share with you a new approach to setting up and managing your compliance function, based on the agile iterative methodology, in a way that’s very similar to how you would organize your tech and product development.
I have already shared my opinion that “just in time” agile compliance is the fastest and most efficient way to scale your FinTech, launch innovating products and keep customers happy. Why? – because the regulatory landscape is a moving target, which is why it’s important not to overinvest time and resources into compliance projects that don’t scale, repel customers, take too long, or otherwise don’t work.
In my almost a decade of working in FinTech and compliance, I have been a part of many regulatory initiatives, licensing processes, new product launches, or geo-expansions and for quite some time, it was true that regulatory analysis and assessments of business-specific implementation have been a big part of my role. However, during 2020, I realized that more and more of my time has been dedicated to topics and issues that are, strictly speaking, above and beyond compliance or regulations, and have everything to do with what I call having the “right cooks in the compliance kitchen”, which means having the right balance of power and responsibilities between your team vs external advisors, manual processes vs automation, and operating with certainty vs uncertainty.
Yes, you heard it right. In addition to some of the core foundational principles of agile compliance, such as lean project management, smooth VIP customer experience, and just in time operational processes, one of the missing pieces of many struggling compliance functions is hiring the right people at the right time and assigning smart incentives and responsibilities to them, which is, essentially, having the right cooks in the kitchen.
It happens every time when you are doing something new for the first time, such as building and expanding your new compliance function or planning a project that nobody in the team has done before.
Which is why I have designed and put together a brand-new-one-of-its-kind workshop for FinTech founders, CEOs, MLROs, Heads of Compliance, CCOs, and other FinTech professionals who are in the process of building and expanding compliance teams and are (likely) suffering from organizational conflicts related to compliance responsibilities and division of labor.
It’s called: Hiring and Managing Compliance
When: January 19th and January 20th, 2021 at 12:00 pm, CET
AGENDA:
Day 1: Who do you hire and when is the right time
- When to hire your first compliance employee?
- When and how do you build a compliance team?
- The difference between compliance and legal
- Pros and Cons of using external consultants and BIG 4 for projects
- Hiring interns and part-time freelancers for compliance-related activities
- What to do during your first 30 days in any new compliance role – your compliance onboarding plan
- How much it should cost
Day 2: Evaluating Compliance Deliverables and Managing Organizational Conflicts
What compliance should deliver and be responsible for as a part of the following activities:
- FinTech Licensing
- Relationships with regulators and auditors
- Opening bank accounts and closing partnerships
- Product Developments and Testing
- Customer Support
- Conflicts, disputes, complains
Typical organizational conflicts and how to deal with them
- Compliance vs Product and Engineering
- Scrutinizing and Approving Customers or Compliance vs Customer Support and User Experience
- Compliance vs Marketing
- Compliance vs Business Development and Sales
So, if you’d like to learn how to avoid the most common organizational slowdowns and conflicts and act with clarity where it comes to hiring and managing compliance resources, you are welcome to join this workshop on January 19-20th, 2020.