Specialised Solutions for Neo-Banks’ Compliance Management

We offer a comprehensive set of risk and compliance solutions tailored to a variety of neo-banks' compliance obligations. We can help you comply with neo-banks' regulations in a commercially oriented and goal-focused manner, providing a tailored approach to neobanking compliance management with regard to your specific circumstances, including:

• Your commercial objectives
• Your digital banking products and financial technology services
• Your business size
• Your technology and human resources
• Your risk appetite
• Your governance structure
• Your client demographics
• Your countries of operation, their applicable laws, and relevant neo-banks' licensing requirements and regulations, including key aspects such as outsourced providers' monitoring, third-party risk management, compliance training, risk management, audit, and assurance.
• Any related compliance obligations, including, but not limited to, neo-banks' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, financial crime prevention obligations, fair trading laws, and more.
• Neo-banks' Compliance Assurance Obligations, including internal control design and testing, implementation of compliance calendars, management plans, risk management, compliance assurance programs and other second and third-line compliance requirements.
• Specific governance, risk, and compliance (GRC) requirements for Neo-Banks, including but not limited to:
  • Client due diligence and onboarding, including electronic Know Your Customer (eKYC)
  • Surveillance and monitoring
  • Recordkeeping
  • Conflict of interest management
  • Regulatory technology (RegTech) integration
  • Internal reporting
  • External reporting
  • Transaction execution
  • Regulatory Filings

 

What Jurisdictions Do Our Compliance Solutions Cover?

Our compliance solutions extend across major financial markets and cover neo-banks' regulation and neo-banks' licensing requirements in the following jurisdictions:

• Australia: Where non-bank neo-banks use an AFSL for Non-Cash Payment (NCP) facilities (e-wallets, stored value, prepaid, payment rails) under the Corporations Act.
• United States: Where neo-banks generally need state Money Transmitter Licences (MTLs) and FinCEN MSB registration to hold balances or move funds. Virtual-asset custody/exchange can trigger state virtual currency permissions (e.g., NY BitLicense).
• United Kingdom: Where neo-banks operate under an Electronic Money Institution (EMI) licence to issue e-money and hold wallet balances, or a Payment Institution (PI) licence for payments-only models, both authorised by the Financial Conduct Authority (FCA) under the Payment Services Regulations and E-Money Regulations, with passporting across the EEA no longer available post-Brexit.
• Singapore: Where payment-only models use SPI/MPI licences under the Payment Services Act for e-money issuance, domestic/cross-border transfers, and merchant acquisition; add Digital Payment Token (DPT) service if crypto is in scope.
• New Zealand: Where neo-banks and payment providers must register on the Financial Service Providers Register (FSPR) under the Financial Service Providers (Registration and Dispute Resolution) Act 2008. Entities providing cross-border transfers, stored-value wallets, or digital trading platforms also need AML/CFT registration with supervision by the Department of Internal Affairs (DIA).
• European Union: Where neo-banks choose EMI (to issue e-money/hold wallet balances) under the E-Money Directive, or PI (payments only) under PSD2, authorised by a national competent authority with EU passporting.
• Popular offshore financial centres, including:

• Cayman Islands: Where VASP registration/licensing covers virtual-asset custody, transfer and exchange; Money Services Business permissions apply for fiat money transmission.
• Bermuda: Where Digital Asset Business (DABA) licences cover custody, exchange, wallet and payment services in digital assets.
• Gibraltar: Where DLT Provider authorisation covers custody/exchange/transfer using DLT for wallet-style services.
• Malta: Where EMI/PI licences cover e-money/payment services; separate VFA authorisations may apply for certain crypto activities.
• British Virgin Islands: Where VASP registration covers virtual-asset services; the Financing and Money Services Act applies to fiat money services.

 

 

What Types of Neo-Banking Providers Do We Support?

 

Neo-Banks’ Compliance Advisory

Our focus areas cover:

• Detailed Compliance Advice: Covering neobanking compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with financial markets regulations and neo-banks' licensing requirements.
• Banking Relationships Advice: On risk and compliance issues related to managing and expanding relationships with banks, liquidity providers, and other financial institutions to help you meet their risk appetite requirements, anti-money laundering and counter-terrorist financing requirements, fraud prevention and recall volume expectations, and other compliance-related and operational standards.
• Operational AML Advice: Advising support, onboarding, KYC, operating and other teams on the day-to-day onboarding and support queue management, effective AML/CFT resource allocations, and operational improvements, helping you maintain the overall customer experience and efficiency while remaining compliant with the neo-banks' AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with neobanking regulations, focusing on internal processes and critical internal controls for effective neobanking compliance management, compliance automation and compliance reporting.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by neo-banks, including regulatory, ML/TF, fraud, data protection, and operational risks. We help you safeguard against potential compliance breaches and comply with risk management obligations under neo-banks' licensing requirements and other applicable laws and regulations.
• Compliance Framework Advice: To help you create or enhance your compliance management framework, identify gaps and areas of improvement, meet the neo-banks' compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• Neo-Banks' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet neo-banks' licensing requirements to become licensed or maintain it.
• Peer Benchmarking and Best Practices: We can help you benchmark your compliance practices against peers and applicable regulatory compliance guidance, identify areas for improvement and adopt best practices for enhanced compliance.
• Government Agencies Liaison Advice: We provide strategic guidance to senior management and compliance teams on maintaining and managing relationships with external bodies, including regulators, AML/CTF supervisors and law enforcement agencies, focusing on long-term compliance strategies and proactive engagement.
• Specific Neo-Banks' Compliance Issues: We can help you resolve specific risk or compliance issues related to neo-banks' regulations and compliance obligations, including but not limited to external audits and reviews, reporting, oversight, difficult clients or transactions, expansion challenges, compliance management issues, process optimisation, regulatory challenges you may encounter and more.
• Further information: You can visit our Regulatory Compliance Consulting Solutions page for a comprehensive list of advisory services we offer to neo-banks and other licensed financial institutions, financial services providers, and regulated businesses.

 

Reporting and Regulatory Liaison Solutions for Neo-Banks’ Compliance

• Regulator Liaison Management: Providing operational guidance to senior management and compliance teams on managing relationships with regulators, AML/CFT supervisors, police bodies, privacy commissioners, and other government entities. This includes handling requests for information, responding to ad-hoc regulatory inquiries, managing findings from audits and investigations, managing compliance with reporting obligations for neo-banks and more.
• Board and Committee Reporting: Facilitating structured reporting workflows for various committees and board delegates, including risk, compliance, and audit committees, focusing on your current compliance status, deviations from your risk appetite, changes in risk ratings and any operational compliance updates to ensure that governance structures are well-informed and aligned with compliance management practices.
• Compliance Performance Metrics: Developing and presenting comprehensive compliance performance metrics to the board or relevant committees, offering insights into your compliance effectiveness and identifying points for improvement in key compliance areas, including compliance training, fraud prevention, compliance monitoring, risk rating and assessment, controls effectiveness, adherence to your compliance calendar, regulatory technology (RegTech) performance, and more.
• Internal Audit Reporting: We can help you increase the effectiveness of the internal audit to make its findings reflect your actual performance against the neo-banks' compliance obligations. This includes developing tailored methodologies for the auditors, preparing the necessary audit evidence and reviewing audit results. The goal is to ensure that audit procedures and outcomes directly contribute to maintaining and enhancing your compliance status and internal controls' effectiveness.
• AML/CFT Reporting Compliance:  We help with the implementation of effective AML/CFT reporting processes, aligning with specific anti-money laundering regulations for internal oversight and prompt escalation of critical AML issues within your business to help the management receive a clear overview of your AML/CFT compliance status.
• Transactional Reporting: Implementing effective transactional reporting procedures to help with neobanking compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the neo-banks' licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with neo-banks' regulations, including neo-banks' licensing requirements, first-line quality assurance results are equally important for effective risk and compliance management. We help organise effective reporting lines, tailor reporting content to your specific circumstances, products, and team size, and establish a structured approach to responding to reporting outcomes.

 

 

Comprehensive Compliance Management Solution for Neo-Banks

Our compliance management services include, but are not limited to, the following:

• Neonbanking' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable neo-banks' licensing requirements, laws, regulations, industry codes, and regulatory guidance.
• Second-Line Compliance Management: We offer a full range of second-line compliance assurance solutions, including internal controls testing for operational, compliance, marketing, legal and other risks, as well as managing issue closure control testing and more.
• Supporting the Board in Strategic Compliance Management: Advising on the necessary compliance resourcing, budget, tools, role structuring, and compliance functions' structure to support your specific business objectives within your risk appetite and risk management framework.
• Compliance Project Management: Effectively coordinating between senior management, committees, legal advisers, risk and compliance functions, outsourced providers, and different departments, including product development, technology, customer support, operations, assurance, marketing, and others, to help you successfully implement compliance projects across the business.
• Customised Governance Solutions: Tailoring governance frameworks and mechanisms to fit your specific governance structure and effectively comply with neo-banks' regulations and other applicable obligations. Whether your business is locally oriented, a start-up, undergoing expansion, part of a multinational group, has a listed parent company or is undergoing restructuring, we tailor the oversight of neobanking compliance management to your business case.
• Stakeholder Management and Reporting: Reporting to the board, committees, shareholders, regulators and other stakeholders. Providing management and the board with comprehensive compliance reports that cover your compliance with neo-banks' compliance obligations, regulatory development summary, compliance-related data and statistics, internal controls testing outcomes and more. Also covering the status of your specific compliance-related projects and compliance goals, relevant compliance KPIs, and more.
• Compliance Calendar Implementation: We design and implement compliance management programs and calendars, covering such areas of neo-banks' compliance obligations as policy and key document reviews, control testing, risk assessment and reviews, vendor reviewers, user system access reviews, assurance activities and more.
• Managing Customer Onboarding and Due Diligence: Implementing commercially oriented and compliant processes for KYC information collecting, Know Your Business (KYB), ML/TF risk assessment, Pep and Sanctions screening, CDD and EDD, especially for higher ML/TF risk clients, to help you comply with AML/CFT compliance obligations for neo-banks.
• AML Transaction Monitoring and Reporting: Developing and implementing a set of business-specific ML/TF alerts and red flags to detect and report suspicious transactions to comply with the neo-banks' AML requirements without making AML/CFT compliance a hindrance to business.
• Information Requests and AML/KYC Data Sharing: Handling information requests from law enforcement agencies, AML/CTF supervisors, and other relevant AML/CTF designated entities, such as your banking partners and other essential service providers (liquidity providers, finance providers, etc.), ensuring that you are fully supported in all AML/CTF compliance-related communications.
• Business Expansion Support: Providing support for your business expansion objectives, recognising and assessing new risks, developing and implementing controls and mitigations for them, as well as addressing new compliance obligations and putting in place practical tools and systems to manage them.
• Neo-Banks' Operational Compliance: Including but not limited to:
  • On-the-Ground Compliance: Conducting compliance management meetings, organising routine and ad hoc compliance reporting, overseeing mitigations and controls testing, leading adjustments and enhancements to your internal controls and protocols when required.
  • Compliance Process and Operations Building: Developing effective and compliant procedures and processes to implement your policies, support your operations across different teams and mitigate operational, regulatory and other risks.
  • Outsourced Provider Performance Monitoring: Setting up initial due diligence and ongoing review frameworks for your outsourced providers to help you meet the required service standards for outsourcing under various neo-banks' compliance obligations, including neo-banks' licensing requirements.
  • Incident Management and Reporting: We can help you set up effective processes for incident reporting, escalations, and management at different levels of your business.

 

Neo-Banks’ Compliance Assurance 

Our services include:

• Compliance Assurance Programs:  We can design and implement your compliance assurance program to maintain enhanced oversight of your compliance with both neo-banks' regulations and your internal compliance and risk appetite thresholds.
• Organisation-Wide Risk Assessments: Helping you focus on the specific risks faced by your business, considering its size, products, client types, jurisdictions of operation, delivery channels, financial institutions you interact with, available technology, and other tools. This includes assessing available mitigations, controls, their effectiveness, residual risk ratings, and the plan to move forward.
• Internal Controls Design: We can develop internal controls for various risk types, including regulatory, fraud, operational, strategic, financial, and other risks. Please visit our Internal Controls Design page for more information. 
• Assurance Testing: We conduct assurance testing to verify that the business complies with its policies, procedures, and neo-banks' compliance obligations, including neo-banks' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable neo-banks' regulations. This process includes a compliance controls testing report and, if necessary, a gap analysis.
• Compliance Quality Assurance: We go beyond merely meeting regulatory requirements. We focus on evaluating and enhancing your risk and compliance management processes to ensure they align with your current and future goals, business model, risk analysis, current client inflow, and more. We also suggest which compliance processes you can use to meet your goals. Here is an example of this service in the AML/CFT area.
• Assurance Reporting: Compiling testing findings and issuing comprehensive compliance assurance reports, which include:

• Identification of any deficiencies or control weaknesses, with clear explanations and potential root cause analysis.
• Recommendations for corrective actions to address identified issues and enhance compliance effectiveness.
• Evaluation of the overall effectiveness of your internal controls and regulatory compliance monitoring program against your desired assurance level.

• Regulatory Inspection Readiness: We can help your business prepare for external audits and regulatory inspections, reducing the risk of adverse findings related to neo-banks' compliance obligations. This includes conducting mock inspections to identify gaps, reviewing documentation and record-keeping practices to ensure all relevant materials are well-organised and readily accessible, and training staff on their roles in the inspection process. We assist in identifying any missing information and weak points, provide interview preparation, and more to ensure readiness for auditor or regulator review.
• Further information: You can visit our Compliance Assurance Solutions page for more information on our third-line compliance assurance review solutions.

 

Compliance Remediation Solutions

Our focus areas include:

• Compliance Remediation Advice: Assisting neo-banks in effectively addressing and rectifying compliance issues, from minor breaches to significant regulatory challenges, including warnings and action plans.
• Remediation Plan Development: Following the independent review, we assist in analysing the findings to identify necessary remedial actions. We then support neo-banks in devising a detailed plan outlining these actions for submission to your regulator or an AML/CFT supervisor, ensuring the plan is both actionable and compliant with regulatory expectations.
• Remediation Plan Commitment: We help neo-banks complete their remediation plans and prevent non-compliance recurrence.
• Executive Attestation Support: Our services include assisting senior executives in preparing the required attestations to your regulator. This involves confirming that all necessary remedial actions have been undertaken and adequate compliance measures are in place, supported by comprehensive documentation and evidence. This option covers assistance with the removal of any licensing restrictions.
• Further Information: For more information, you can visit our Compliance Remediation Solutions page.

 

Internal Controls Testing and Neo Banking Compliance Management

When it comes to reality versus a nice policy or procedure with nothing else to show for it, it’s often a case where a policy says A, but reality says B. One might ask, why didn’t we test our internal controls before? Or, why didn’t we do it properly? There’s nothing worse than faking compliance instead of actually doing it.

Our second line of compliance defence solutions covers the development, testing, and enhancement of a wide range of controls to ensure compliance with various laws and regulations governing neo-banks' compliance obligations.

We go beyond merely quoting neo-banks' regulations or a selection of licensing requirements, then adding Excel sheets painted in different colours as a supposed source of truth with nothing to show for it.

• We test them.
• We link them to your risk appetite and core risk management documentation.
• We provide relevant suggestions and analysis tailored to your business.

Some of our focus areas for testing the neo-banks' compliance requirements include:

Regulatory Compliance and Licensing Controls

• Compliance Management: Businesses that have to comply with online bank regulations are expected to have robust compliance management systems, including conflict of interest management and staff training, to meet neo-banks' licensing requirements.
• Liquidity Management: Entities subject to digital bank compliance obligations should maintain sufficient liquidity to meet operational needs and withdrawal demands, aligning with APRA's standards in Australia and the ECB's requirements in the EU.
• Capital Adequacy: Neo-banks are expected to maintain adequate capital to cover operational and credit risks, particularly under frameworks like Solvency II in the EU and APRA's guidelines in Australia.
• Financial Auditing: It is generally compulsory for neo-banks that are subject to licensing regimes to engage qualified auditors who conduct regular financial audits to validate financial health and regulatory compliance, a common requirement across jurisdictions.
• Cross-Border Application of Regulations: Entities subject to digital bank compliance obligations should adhere to international banking regulations and standards when offering services in multiple jurisdictions, ensuring compliance with neo-bank regulations.
• Regulatory Technology (RegTech) Implementation: Neo-banks should utilise advanced regulatory technology solutions to automate compliance processes, ensuring real-time monitoring and reporting of regulatory obligations. This includes the use of AI and machine learning for AML/CFT compliance.
• RegTech Integration: Entities subject to digital bank compliance obligations are expected to integrate RegTech solutions into their existing systems to enhance compliance accuracy and efficiency.

Operational Oversight Controls

• Outsourcing Oversight: Neo-banks should control third-party services for technology, payment processing, or customer support to comply with regulatory standards such as GDPR in the EU and the Privacy Act in Australia.
• Risk Management: Entities that have to comply with online bank regulations should identify and mitigate financial, operational, and cybersecurity risks, aligning with guidelines from regulatory bodies like the OCC in the US and the PRA in the UK.
• Governance Arrangements: Businesses that have to comply with online bank regulations should establish effective management structures and decision-making processes to comply with governance standards set by authorities like APRA and the ECB.
• Senior Management Accountability: Neo-banks should assign specific responsibilities to senior management to ensure accountability for compliance and risk management practices, a common expectation in jurisdictions like the UK and Australia.
• Operational Resilience: Entities subject to digital bank compliance obligations are expected to ensure the continuity of banking operations, especially in the digital banking context, adhering to resilience standards set by regulatory bodies across different regions.
• Technology Risk Management: Neo-banks should manage the risks associated with digital banking platforms, including data security, system reliability, and protection against cyber threats, in line with regulations from entities like MAS or the FCA.
• Fintech Risk Management: Neo-banks offering fintech services should implement robust risk management practices to identify, assess, and mitigate risks associated with innovative financial technologies.
• Mobile Banking Security: Neo-banks should implement stringent security measures for mobile banking platforms, including multi-factor authentication, encryption, and biometric verification, to protect against cyber threats.
• Mobile Application Vulnerability Assessments: Businesses that have to comply with online bank regulations should conduct regular vulnerability assessments and penetration testing on mobile banking applications to identify and mitigate security risks.

 

Market Integrity and Transparency Controls

• Market Conduct Standards: Entities subject to digital bank compliance obligations should ensure fair and transparent banking practices, particularly in customer interactions, product offerings, and advertising.
• Fair Dealing Principles: Neo-banks are expected to guarantee fair treatment of customers, offering transparent terms and conditions, especially for loan products and deposit services.
• Conduct and Disclosure Standards: Businesses subject to digital bank compliance obligations should maintain high standards of conduct and ensure clear, effective disclosures to customers, aligning with consumer protection laws and regulations in various jurisdictions.
• Service Provision Standards: Entities that have to comply with online bank regulations should provide banking services efficiently, honestly, and fairly, a standard expectation across regulatory frameworks.
• Client Asset Protection: Neo-banks are expected to safeguard client funds and ensure they are segregated from the bank's operational funds, in compliance with regulatory requirements.
• Wallet Compliance: Neo-banks offering digital wallet services are expected to implement robust KYC and AML controls to prevent fraud and money laundering activities. One of the main features here is linking the supplied identity documents to the platform user who provided them, as there is very little personal interaction between a neo-bank and their user due to the absence of physical branches.
• Digital Wallet Transaction Monitoring: Entities subject to digital bank compliance obligations should establish real-time transaction monitoring systems for digital wallets to detect and prevent suspicious activities.

 

 

Resource Management Controls

• Resource Adequacy: Entities subject to digital bank compliance obligations should maintain adequate financial, technological, and human resources to support effective operations and regulatory compliance.
• Professional Competence: Neo-banks are expected to ensure that staff, particularly those in risk management, compliance, and customer service, possess the necessary skills and knowledge to fulfil their roles effectively.

 

Reporting Controls

• Regulatory Reporting: Businesses that have to comply with online bank regulations should report operational, financial, and compliance information to regulatory bodies, ensuring transparency and adherence to regulatory standards.
• Record-Keeping: Neo-banks should maintain accurate and accessible records of customer transactions, account information, and compliance efforts, facilitating audits and regulatory reviews.
• Cybersecurity Incident Reporting: Neo-banks should establish controls for timely reporting of cybersecurity incidents to relevant authorities.

Transactional Controls

• Authorisation and Verification Procedures: Entities subject to digital bank compliance obligations should verify customer identities and transactions, aligning with AML/KYC regulations in jurisdictions like the EU or the US.
• Conflict of Interest in Transactions: Neo-banks should identify and manage potential conflicts of interest, ensuring decisions are made in the best interests of customers and comply with regulatory standards.
• API Integration Compliance and API Security Standards: Neo-banks should ensure that APIs used for integrating various financial services comply with security standards to protect data integrity and prevent unauthorised access.
• API Regulatory Compliance: Businesses that have to comply with online bank regulations are expected to ensure that APIs adhere to regulatory requirements, including data privacy laws and PSD2 directives for open banking in the EU.

 

Product and Service Management Controls

• Product Suitability: Businesses that have to comply with online bank regulations should ensure that banking products and services meet the needs of target customers and comply with regulatory standards regarding fairness and transparency.
• Product Lifecycle Oversight: Neo-banks are expected to manage the development, launch, and retirement of banking products, ensuring they remain compliant with changing regulations and market needs.
• Execution Quality: Entities subject to digital bank compliance obligations should guarantee efficient and accurate processing of banking transactions, customer applications, and service requests.
• Data Protection and Privacy: Neo-banks should protect customer data in compliance with data protection regulations like GDPR in the EU or the Privacy Act in Australia, ensuring customer trust and regulatory compliance.
• Comprehensive Compliance Frameworks: Neo-banks are expected to develop and maintain comprehensive compliance frameworks that cover all regulatory requirements, including AML/CFT, data protection, and consumer protection laws.
• Periodic Compliance Reviews: Entities subject to digital bank compliance obligations should conduct regular reviews and updates of their compliance frameworks to ensure alignment with evolving regulations.

 

Licensing Solutions for Neo-Banks

• Financial Licensing Application Support: We provide comprehensive support for a wide range of neo-banks' licensing applications, including:

• AFSL Licensing in Australia: We assist neo-banks in obtaining an AFSL for issuing non-cash payment methods, including e-wallets, prepaid cards, and stored value facilities.
• FSP and DTP Registration in New Zealand: We guide digital banks and fintech platforms through registration as FSPs and DTPs, ensuring compliance with DIA-supervised AML/CFT obligations.
• EMI and PI Authorisation in the U.K.: We help neo-banks apply for FCA EMI or PI authorisations and comply with FCA crypto-assets regulations.
• MTL Registration in the U.S.: We provide consultancy for obtaining state Money Transmitter Licences (MTLs) and registering with FinCEN as MSBs.
• EMI and PI Licensing in the EU: We support applications for EMI or PI licences with national regulators under the PSD2 framework.
• Digital Bank and Payment Institution Licensing in Singapore: We assist with MAS applications for Digital Bank or Wholesale Bank licences, and for Standard or Major Payment Institution (SPI/MPI) licences.
• Cayman Islands Money Services Licence: We assist with Cayman Islands Monetary Authority (CIMA) applications under the Money Services Act for wallets, remittance, and stored value facilities.
• Bermuda Digital Asset Business Licence: We support applications under the Digital Asset Business Act 2018 with the Bermuda Monetary Authority (BMA), covering custody, payments, and token-based products.
• Gibraltar DLT Provider Licence: We advise on GFSC applications under the Financial Services (Distributed Ledger Technology Providers) Regulations 2020 for blockchain-based remittance and payment solutions.
• Malta Financial Institution Licence: We assist with MFSA applications under the Financial Institutions Act for EMI-style and payment institution activities.
• BVI Financing and Money Services Licence: We guide applicants through BVI Financial Services Commission requirements under the Financing and Money Services Act 2009 for e-wallet and remittance operations.
• Seychelles Payment Service Provider Licence: We support Financial Services Authority applications under the National Payment Systems Act for PSPs and mobile payment operators.

• International Governance Alignment: We provide strategic advice on aligning governance models for neo-banks operating across multiple jurisdictions to meet diverse regulatory expectations while maintaining operational efficiency and regulatory compliance.

 

Policies and Procedures for Neo-Banking Compliance Management

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective neo-banking compliance management.
• Effective Procedures for Neo-Banking Compliance Management: We draft and enhance a detailed set of procedures and protocols to meet the distinct needs of your business, focusing on efficient compliance, your business goals, and applicable neo-banks' compliance requirements.
• Examples: These policies and procedures include, but are not limited to:

 

Operational Compliance

• Compliance Management Frameworks
• Compliance Monitoring Programs
• Compliance Calendars and Checklists
• Complaints Handling and Dispute Resolution Policies
• Compliance Training Manuals and Programs, as part of our regulatory compliance training solutions
• Obligation Registers
• Depositor Compensation Scheme Policy
• Margin Account Negative Balance Write-Off Procedure
• Incident Reporting Policies and Procedures
• Outsourcing Policies and Vendor Risk Management policies as part of our outsourced provider's compliance management solutions
• New Client Account Opening Policies and Procedures, as part of our customer onboarding solutions

 

Governance and Oversight

• Board Charters, Risk, Audit and Compliance Committee Charters, as part of our corporate governance solutions
• Codes of Conduct
• Delegations Registers
• HR Manuals and Policies
• ESG Compliance Policies
• Conflict of Interest Policies

 

Risk Management

• Risk Management Frameworks as part of our risk management solutions
• Risk Assessment Guidelines and Methodologies
• Internal Control Testing Methodologies
• Risk Registers and specialised risk registers like Health and Safety Risk Registers
• Whistleblowing Policies
• Cybersecurity Risk Management Policies

 

Audit and Assurance

• Compliance Assurance Programs as part of our compliance assurance solutions
• Internal Audit Policies and Programs as part of our internal control testing solutions
• Regulatory Reporting Procedures

 

Client and Market Conduct

• Marketing and Advertising Policy
• Staff Dealing and Insider Trading Policy
• Deposit Interest Rate Policy and Procedures
• Fair Dealing Policy

 

AML/CFT and Financial Crime Compliance

• AML/CFT Compliance Programs
• AML/CFT Risk Assessment
• Sanctions Compliance policies and procedures
• Fraud Prevention Protocols and Controls as part of our fraud prevention solutions
• ABC Policies

 

Privacy and Data Management

• Client Data Protection Policies
• Record-keeping Policies and Procedures and/or Data Governance Policies as part of our record-keeping compliance solution
• External Privacy Policies
• Internal Data Protection Compliance Programs

 

 

Compliance Training and Capacity Building

We focus on practical compliance and the application of training to real-world compliance scenarios and challenges that neo-banks generally face. Our services include:

• Customised Compliance Training Solutions:  Specialised compliance training sessions for various teams, including management, compliance, operations, sales, and customer relations, focusing on neo-banks' regulations, applying neobanking compliance management practices to your circumstances, risk awareness, and more.
• Up-to-date Regulatory Compliance Updates:  Keeping compliance officers, managers, CROs, COOs, and other Risk and Compliance team members informed of changes in neo-banks' licensing requirements and regulations, AML/CFT updates, and changes in regulatory guidance.
• Data Analysis for Effective Compliance Monitoring: Covering training on compliance-related, data-based analysis and its results, including risk rating, internal control adjustments, resource and focus reallocation, and more.
• Workshops on Emerging AML Trends and Red Flags: Updating on the new AML trends, red flags, typologies, and AML/CFT requirements for neo-banks. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented neo-banks' compliance, capacity planning, and resource allocation, covering:

• Neo-Banks' Regulations
• Internal and external compliance reporting
• Effective governance over risk and compliance functions
• Organisation-wide risk assessment, risk rating methodologies and the development, management, and testing of corresponding internal controls, including controls testing methodologies and practical techniques.
• Neo-banks' compliance reality, including outsourced provider monitoring, UAV management, incident management, product suitability assessments, advertising and marketing compliance, improvements in the client onboarding journey, transaction monitoring processes, and more.

• Further information: You can visit our Compliance Training Solutions page for more information on the compliance training services we offer to licensed financial institutions and financial service providers.

 

Neo-Banks and AML/CTF Compliance

We offer a complete set of solutions covering neo-banks' anti-money laundering (AML), financial crime and counter-terrorism financing (CTF) compliance. Our solutions include:

• Customer due diligence, screening, and customer onboarding solutions
• Development of transaction monitoring frameworks tailored to neo-banks' specific ML/TF red flags and your business specifications
• AML advisory covering neo-banks' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for neobanking providers
• Internal and statutory AML/CFT audit solutions for neo-banks
• Financial crime prevention framework development focusing on common fraud risks faced by neo-banks
• For more information, please visit our specialised AML Compliance Solutions page for Neo-Banks

 

Neo-Banks’ Compliance Technology Integration

Our services cover compliance aspects concerning the integration of technology for risk and compliance management, transactional reporting (where applicable), usage of AI, technology outsourcing, and compliance aspects of third-party risk management for neo-banks, including:

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable neo-banks' compliance obligations
• Implementation assistance across the organisation
• Streamlining operational workflows: For routine compliance tasks like data collection, reporting, and risk assessments
• AML/CFT Compliance Technology: Covering customer digital onboarding, E-KYC, PEP and sanctions screening, transaction monitoring, etc.
• Integration of neo-banks' compliance obligations into an effective CRM system
• Record-Keeping Obligations: Helping you choose and integrate the necessary tools to comply with the record-keeping requirements under various laws and neo-banks' regulations

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting neo-banks in establishing robust data governance procedures, programs, and protocols that align data collection, storage, and usage practices with relevant data privacy regulations, such as GDPR, CCPA, and other applicable laws. These measures safeguard sensitive client and business information from unauthorised access, breaches, and misuse.
• Privacy Policy Compliance Monitoring: Helping you implement privacy policies that reflect the latest data protection legislation, supported by continuous compliance monitoring tools to maintain the highest data privacy standards.
• Record Maintenance Protocols:  We assist in developing and implementing effective procedures for maintaining necessary records, covering neo-banks' compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  Neo-Banks' regulations often require records to be readily available for inspection by regulators, AML/CFT supervisors, tax agencies, and other relevant authorities. This extends to information kept by your outsourced service providers. We help you organise your record-keeping processes to meet these needs.

 

ISO Standards and Neo-Banks’ Compliance

• Cross-Reference Mapping: Integrating ISO standards such as ISO 27001, ISO 9001, and ISO 22301 into an existing compliance framework and linking specific sections of ISO standards to corresponding procedures in your internal policies and procedures.
• Pre-Audit Preparation: Coordinating ISO controls testing across different parts of the business.
• Leading evidence collection across the different departments to cover relevant compliance areas such as planning, governance, organisational controls, operational controls, technological controls, and physical controls through structured workflows.
• Digital Compliance Repository: Helping you utilise a centralised digital repository for storing all compliance-related documents and evidence, making it easily accessible for audit purposes and compliance verification.
• ISO Audit Liaison:  Acting as a liaison between your team and the auditors, coordinating information requests, and ensuring all the necessary documentation is readily available.
• Post-Audit Remediation Management: We can lead the implementation of your remediation plan and support corrective actions to address all audit findings effectively.

 

Regulatory Change Management Solutions

Empower Your Business with Proactive Regulatory Change Management:

• Stay Ahead of the Curve:  We actively monitor regulatory updates from global financial authorities like MAS, ASIC, FMA, FCA, SEC, and other regulators for neo-banks' compliance changes and updates to evaluate the implications of regulatory changes.
• Impact Assessment and Mitigation Strategies: We analyse the potential impact of regulatory changes on neobanking compliance management frameworks and operational processes. We then collaborate with you to develop effective mitigation strategies that support continued compliance and minimise disruption.
• Seamless Implementation and Change Management:  We guide neo-banks through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.