Neobank Licensing Solutions | Pre-licensing Assessment | Neobank Licence Application Management | Post-licensing Risk and Compliance Management

We offer a comprehensive set of solutions to help you obtain and maintain a neobank licence, tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• Regulated neobanks' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the neobanks' licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the neobanks' licensing process, including but not limited to the following aspects:

• Neobank Licence Guidance: Advising on a wide range of aspects associated with neobank licence as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the neobank licence conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the neobanks' licensing regime
• Neobank Licence Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Jurisdictional Coverage of our Neobank Licence Solutions

Our compliance solutions extend across major financial markets and cover neo‑banks’ regulation and licensing requirements in the following jurisdictions. There is no stand‑alone “neo‑bank” licence in most jurisdictions. So choosing an appropriate licence is about understanding the specific business model:

• Australia: Neo‑banks issuing non‑cash payment methods (e‑wallets, prepaid cards, stored value facilities) also require an Australian Financial Services Licence (AFSL) from ASIC under the Corporations Act 2001.
• New Zealand:  Providers of non‑bank services (payments, remittances, e‑wallets) register as Financial Service Providers (FSPs) under the Financial Service Providers (Registration and Dispute Resolution) Act 2008 and comply with AML/CFT registration. Fintech platforms offering digital asset trading must register as Digital Trading Platforms (DTPs) under the AML/CFT regime, supervised by the Department of Internal Affairs.
• United Kingdom: Neo‑banks focused on payments can operate under an EMI authorisation or PI authorisation from the Financial Conduct Authority. Those operating in cryptospace have specific obligations under the FCA crypto-assets regime.
• United States: Neo-banks typically operate as money transmitters or e-money providers, requiring state-level Money Transmitter Licences (MTLs). Some also register with FinCEN as Money Services Businesses (MSBs). Full banking charters are uncommon and usually involve partnering with existing banks.
• European Union: Neo-banks may apply for an Electronic Money Institution (EMI) licence or Payment Institution (PI) licence with a national regulator under the PSD2 framework.
• Singapore: MAS issues Digital Bank and Wholesale Bank licences under the Banking Act. Payment-only providers register for Standard or Major Payment Institution (SPI/MPI) licences under the Payment Services Act.
• Popular Offshore Financial Centres:

• Cayman Islands: Where neo-banks and fintech providers require a Money Services Licence under the Money Services Act, issued by the Cayman Islands Monetary Authority (CIMA).
• Bermuda: Where digital asset businesses obtain a Digital Asset Business Licence under the Digital Asset Business Act 2018, regulated by the Bermuda Monetary Authority (BMA).
• Gibraltar: Where fintech and blockchain platforms can apply for a DLT Provider Licence under the Financial Services (Distributed Ledger Technology Providers) Regulations 2020, supervised by the Gibraltar Financial Services Commission (GFSC).
• Malta: Where payment providers and wallet operators may apply for a Financial Institution Licence under the Financial Institutions Act, regulated by the Malta Financial Services Authority (MFSA).
• British Virgin Islands (BVI): Where e-wallet and money transmission operators require a Financing and Money Services Licence under the Financing and Money Services Act 2009, regulated by the BVI Financial Services Commission.
• Seychelles: Where mobile money and payment service operators obtain a Payment Service Provider Licence under the National Payment Systems Act, overseen by the Financial Services Authority.

 

Service Coverage

We offer comprehensive support for a wide range of neobank licence applications tailored to meet the specific needs of the following businesses:

• Digital-Only Banks
• Mobile-First Banks
• Fintech Platforms
• Payment Service Providers (PSPs)
• Electronic Money Institutions (EMIs)
• Cryptocurrency Banks
• Challenger Banks
• White-Label Banking Providers

You can find more information about our neobank licence solutions below:

 

Neobanks’ Licensing Preparation

Pre-licensing Compliance Assurance

Our neobank licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for a neobank licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the neobanks' licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your neobank licence, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• Neobank Licence Application Plan: We help you establish a roadmap to effectively meet the neobank licence requirements

 

 

Neobank Licence Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our neobanks' licensing solution covers:

• Compliance Model Selection: To help you best comply with the neobanks' licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for neobanking providers and other applicable regulated neobanks’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

Entering Neobanks’ Licensing Environment

We help businesses transition from an unregulated environment to operating under the neobanks' licensing regime, helping them meet their obligations as a neobank licence holder.

We also assist businesses that are already regulated in aligning their existing risk and compliance management structures with the neobanks' licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing neobank providers operating in unregulated markets
• Regulated neobanks expanding into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer neobanking services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with regulated neobanks’ obligations globally.

 

Neobank Licence and Wholesale Markets

Getting a neobank licence may not always be the best fit for all. For example, a retail market expansion may not always align with your goals or the products you offer.

Operating in the wholesale environment can sometimes be a more suitable option. We offer a wider range of risk and compliance management solutions to assist neobanks that:

• Operate in the wholesale markets
• Operate under exemptions from the neobanks' licensing regime
• Operate under a neobank licence limited to sophisticated, eligible, and wholesale investors

We help these businesses comply with the regulatory compliance obligations that still apply despite the absence of the neobanks' licensing regime or apply under the wholesale-only licensing framework, including:

• Advertisement Rules
• Fair Dealing Regulations
• Risk Management
• Outsourced Providers' Oversight
• Restrictions on offering services to retail investors (an integral part of the neobanks' licensing regime)
• Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
• Data Management Laws and Regulations

 

 Neobank Licence Application

We assist with your licence application through ongoing engagement in the neobanks' licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your neobank licence application.
• Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Neobanks' Licensing Process and Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving Neobank Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our neobank licence solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for Neobank Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with neobanks' licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your neobank licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.

• Licensing Issues Handling: We address common licensing issues encountered during the neobanks' licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for licensed neobanks. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated Neobanks’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the neobanks' licensing regime and other regulatory compliance obligations. You can visit our Compliance Advisory page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page for Neobanks.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:
• Regulated neobanks’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• Neobanks’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for neobank providers. For more information, visit our Specialised AML/CFT Solutions page for Neobanks.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for Neobank Licence Holders

Neobank licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support in the different areas. The list below is not exhaustive:

Neobank Licence and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more.
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil regulated neobanks’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the neobanks' licensing requirements.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the neobanks' licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the neobanks' licensing regime.
• Digital Payment Token Services: We can assist in developing controls to comply with regulations for digital payment tokens, cryptocurrencies, and digital assets, including obligations under the neobanks' licensing regime and AML/CFT requirements for transaction monitoring and reporting.

 

Neobank Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with neobanks' licensing obligations for overseeing outsourced services, covering related obligations under AML/CFT compliance, ISO requirements, and more.
• Structures for Governance: We can help you establish effective governance structures to comply with regulated neobanks’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with regulated neobanks’ obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet regulated neobanks’ obligations for operational resilience, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the neobanks' licensing regime.

 

Neobank Licence and Market Integrity/Transparency Requirements

• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with neobanks' licensing standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with neobanks' licensing obligations to protect and segregate client assets.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

Neobank Licence and Resource Management Obligations

We can help you comply with the following requirements of the neobanks' licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and neobank regulations.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

 

Neobank Licence and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Neobanks' licensing obligations
  • Neobanks’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
  • Regulated Neobanks’ obligations under financial market conduct laws and regulations
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the neobanks' licensing regime, applicable operational standards, and more.