Specialised Solutions for Non-bank Deposit Takers’ Compliance Management

We offer a comprehensive set of risk and compliance solutions tailored to a variety of non-bank deposit takers’ compliance obligations. We can help you comply with prudential regulations in a commercially oriented and goal-focused manner, providing a tailored approach to non-bank deposit takers' (NBDT)  compliance management with regard to your specific circumstances, including:

• Your commercial objectives
• Your savings options and related products
• 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 non-bank deposit takers’ licensing requirements and regulations, including key aspects such as outsourced providers' monitoring, compliance training, risk management, audit, and assurance.
• Any related compliance obligations, including, but not limited to, non-bank deposit takers’ obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• Non-bank deposit takers' compliance assurance obligations, including internal control design and testing, implementation of compliance calendars, management plans, compliance assurance programs and other second and third-line compliance requirements.
• Specific operational compliance requirements for non-bank deposit takers, including but not limited to:
  • Client due diligence and onboarding
  • 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 prudential regulations and non-bank deposit takers’ licensing requirements in the following jurisdictions:

• Australia: Where non-bank financial institutions that accept customer deposits are classified as Authorised Deposit-taking Institutions (ADIs) and regulated by the Australian Prudential Regulation Authority (APRA) under the Banking Act 1959.
• United States: Where NBDT institutions that focus primarily on residential mortgages are classified as Savings and Loan Associations and regulated by the Office of the Comptroller of the Currency (OCC) under the Home Owners' Loan Act.
• United Kingdom: Where institutions that offer banking and savings products to their members are classified as Building Societies and regulated under the Building Societies Act 1986.
• Singapore: Where institutions that are licensed to take deposits and provide financing are classified as Finance Companies and regulated by the Monetary Authority of Singapore (MAS) under the Finance Companies Act.
• New Zealand: Where institutions that accept deposits but do not hold a banking licence are classified as Non-Bank Deposit Takers (NBDTs) and regulated by the Reserve Bank of New Zealand (RBNZ) under the Deposit Takers Act 2023 and some provisions of the Non-bank Deposit Takers Act 2013 and Banking (Prudential Supervision) Act 1989. The transitional period between the old and new acts is expected to be completed around 2027-2028. The financial service providers that obtain the NBDT licence are expected to be supervised by the Financial Markets Authority (FMA) under the Financial Markets (Conduct of Institutions) Amendment Act 2022 from 2025.
• Low Tax Jurisdictions: Our NBDT compliance management in this area covers most NBDTs that provide financial services to high-net-worth individuals and wholesale investors from the following offshore financial markets:

• • Cayman Islands: Where institutions providing non-bank deposit-taking services are classified as Class B or Class C Banks and regulated by the Cayman Islands Monetary Authority (CIMA) under the Banks and Trust Companies Law.
  • Bermuda: Where non-bank financial institutions are regulated under the Banks and Deposit Companies Act 1999 by the Bermuda Monetary Authority (BMA).
  • British Virgin Islands: Where non-bank financial institutions providing deposit-taking services are regulated under the Banks and Trust Companies Act 1990 by the British Virgin Islands Financial Services Commission (BVI FSC).
  • Isle of Man: Where non-bank financial institutions are regulated under the Financial Services Act 2008 by the Isle of Man Financial Services Authority (IOMFSA).

 

What Types of Non-Bank Deposit Takers Do We Support?

Our non-bank deposit takers' compliance solutions cover the following types of financial institutions:

• Finance Companies: Providing deposit-taking and financing services under strict regulatory oversight, ensuring compliance with local and international regulations.
• Credit Unions: Offering savings and loan products to their members while adhering to specific regulatory requirements to maintain financial stability and consumer trust.
• Building Societies: Providing members with banking and savings products focusing on regulatory compliance and transparency.
• Savings and Loan Associations: Specialising in residential mortgage services and regulated under specific financial laws to ensure safe and sound operations.
• Mutual Savings Banks: Catering to community-based savings and lending needs, adhering to regulatory standards to protect depositors.
• Community Development Financial Institutions (CDFIs): Focusing on providing financial services in underserved markets, ensuring compliance with specific regulations to support community development.
• Related Financial Activities: Our services extend to compliance management and risk mitigation in their lending and investment operations, following the receipt of investors' deposits, including compliance with regulations around protected deposits.

 

Non-Bank Deposit Takers’ Compliance Advisory

Our focus areas include:

• Detailed Compliance Advice: Covering NBDT compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with financial markets regulations and non-bank deposit takers’ 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 non-bank deposit takers’ AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with prudential regulations, focusing on internal processes and critical internal controls for effective NBDT compliance management.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by non-bank deposit takers, 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 non-bank deposit takers’ 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 non-bank deposit takers’ compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• Non-Bank Deposit Takers' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet non-bank deposit takers’ 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 Non-Bank Deposit Takers' Compliance Issues: We can help you resolve specific risk or compliance issues related to prudential 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 non-bank deposit takers and other licensed financial institutions, financial services providers, and regulated businesses.

 

 

Reporting and Regulatory Liaison Solutions for Non-Bank Deposit Takers’ 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 non-bank deposit takers 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 non-bank deposit takers’ 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 NBDT compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the non-bank deposit takers’ licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with prudential regulations, including non-bank deposit takers’ 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 Non-Bank Deposit Takers

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

• Non-Bank Deposit Takers' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable non-bank deposit takers' 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 prudential 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 NBDT 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 non-bank deposit takers’ 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 non-bank deposit takers’ 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 non-bank deposit takers.
• 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 non-bank deposit takers’ 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.
• Non-Bank Deposit Takers' 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 non-bank deposit takers’ compliance obligations, including non-bank deposit takers' 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.

 

Non-Bank Deposit Takers’ 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 prudential 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 non-bank deposit takers’ compliance obligations, including non-bank deposit takers' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable prudential 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, your risk analysis, your 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 non-bank deposit takers’ 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 non-bank deposit takers 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 non-bank deposit takers 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 non-bank deposit takers 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 NBDT 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 non-bank deposit takers' compliance obligations.

We go beyond merely quoting prudential 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 internal controls include:

 

Regulatory Compliance and Licensing Controls

• Compliance Management:  Non-bank deposit takers are expected to have robust compliance management systems, including conflict of interest management and staff training.
• Liquidity Management: NBDT businesses should ensure adequate liquidity to meet financial obligations promptly, especially given the nature of deposit-taking.
• Capital Adequacy: NBDT institutions are expected to maintain sufficient tangible financial resources for maintaining financial stability, as outlined by APRA and MAS standards.
• Financial Auditing: Licensed non-bank deposit takers should engage qualified auditors to conduct regular financial audits to ensure accuracy in financial reporting and compliance.
• Regulated Counterparty Engagement: NBDTs should ensure adherence to regulated counterparty engagement rules, particularly in the UK and Australia, where they might engage with other financial institutions for services like loan origination or payment processing.
• Cross-Border Application of Regulations: Non-bank deposit taking institutions are expected to comply with cross-border application regulations, especially when operating in multiple jurisdictions or engaging in international transactions.
• Compliance with E-Money Regulations: NBDT businesses offering e-money services in jurisdictions like the UK and Singapore should comply with specific e-money regulations.

 

Operational Oversight Controls

• Outsourcing Oversight: NBDT institutions should maintain control and oversight over outsourced functions to ensure they do not compromise regulatory obligations, clients' information security, and other critical aspects of operations.
• Risk Management: Non-bank deposit takers are expected to establish comprehensive risk frameworks and procedures to identify, assess, and manage operational and market risks, with specific emphasis on credit risk and operational risk management.
• Governance Arrangements: Non-bank deposit institutions should have effective governance structures in place to ensure compliance with prudential regulation, overseeing operations and ensuring responsible management and decision-making.
• Senior Management Accountability: Specific responsibilities should be assigned to senior managers to ensure accountability for conduct and competence within an NBDT.
• Operational Resilience: NBDT businesses must ensure the resilience of critical business services, planning for continuity amidst disruptions, especially important for digital or fintech-oriented non-bank deposit takers.
• Technology Risk Management: Non-bank deposit institutions must manage risks associated with technology, particularly in deposit-taking and lending services, covering areas such as cybersecurity and system reliability.
• Financial Inclusion Strategies: For NBDTs focusing on expanding access to financial services, controls to ensure products and services cater to underserved or unbanked populations are relevant.
• Conflict of Interest Management: Non-bank deposit takers should have robust processes in place to identify, manage, and mitigate conflicts of interest to protect clients' interests and maintain trust.
• Digital Service Delivery: NBDT institutions, especially neo-banks and fintech firms, should implement controls around digital service delivery, cybersecurity, and online customer engagement to ensure secure and reliable operations.

 

Market Integrity and Transparency Controls

• Market Conduct Standards: Non-bank deposit takers must ensure market conduct is fair, transparent, and free from abuse, including manipulation or insider trading.
• Fair Dealing Principles: NBDT businesses must adhere to principles ensuring fair treatment of clients, with clear communication and transparent dealings.
• Conduct and Disclosure Standards: Non-bank deposit institutions should maintain high standards of conduct and ensure that disclosures to their clients are clear, accurate, and effective.
• Service Provision Standards: NBDT businesses are expected to provide services efficiently, honestly, and fairly, ensuring high standards in service delivery.
• Client Asset Protection: Non-bank deposit takers must safeguard client funds, ensuring they are segregated from the institution's own funds, with clear rules for their use and handling.
• Dispute Resolution: Non-bank deposit institutions should have mechanisms for resolving client disputes and ensuring proper compensation, particularly for retail clients.
• Interest Rate Transparency: NBDT institutions should ensure that interest rates, fees, and charges are transparently communicated to customers, preventing any hidden costs or misleading practices.
• Regulatory Sandbox Participation: For NBDTs innovating with new financial products or services, controls related to participation in regulatory sandboxes (where available) can facilitate safe innovation under regulatory oversight.
• Climate Risk Management: Non-bank deposit takers should assess and manage the impact of climate change on their operations and financial stability, particularly in forward-looking jurisdictions like the EU.

 

Resource Management Controls

• Resource Adequacy: Non-bank deposit takers should ensure they have adequate financial, technological, and human resources to operate effectively and comply with regulations.
• Professional Competence: Non-bank deposit businesses must ensure key personnel possess the necessary competence, knowledge, and skills to fulfil their roles effectively.
• Advisor and Representative Competence: Staff involved in deposit-taking activities must receive adequate training and demonstrate competence, maintaining a high standard of service.
• Continuing Education and Professional Development: Non-bank deposit institutions must engage in ongoing professional development activities to stay up-to-date with industry changes and maintain their licenses.
• Cultural and Ethical Standards: NBDT businesses should instill a strong ethical culture and commitment to fair dealing within the organisation, given the trust-based nature of deposit-taking and lending.

 

Reporting Controls

• Regulatory Reporting: Non-bank deposit takers must submit regular reports to the relevant regulatory authorities detailing financial status, compliance status, deposit volumes, liquidity positions, and more to ensure ongoing compliance with regulations.
• Record-Keeping: NBDT institutions must maintain accurate records of all business transactions and financial matters for transparency and accountability under various laws, including AML/CFT regulations.
• Sustainability Reporting: Non-bank deposit businesses committed to sustainable practices should establish controls for reporting on ESG (Environmental, Social, and Governance) initiatives and impacts, aligning with regulatory and consumer expectations around sustainability.

 

Product and Service Management Controls

• Product Suitability: NBDT institutions must ensure that products offered are suitable for clients, considering their financial needs and risk tolerance.
• Product Lifecycle Oversight: NBDT businesses should ensure that deposit products comply with regulatory requirements and meet consumer needs throughout their development, launch, and ongoing management.
• Execution Quality: Non-bank deposit takers must ensure efficient and accurate processing of deposit applications, disbursements, and customer inquiries to maintain high standards of service.
• Data Protection and Privacy: NBDT institutions must adhere to strict data protection regulations to safeguard sensitive consumer data and ensure compliance with data protection laws.
• Accessibility and Inclusivity: Non-Bank Deposit Businesses should implement controls to ensure that products and services are accessible to a wide range of customers, including those with disabilities, aligning with broader social responsibility goals.

 

Transactional Controls

• Electronic Trading Risk Requirements: NBDT Institutions utilising electronic systems for deposit and lending services must manage associated risks through pre-trade risk controls, system safeguards, and other measures to maintain market integrity and resilience.
• Deposit Account Opening and KYC: Non-Bank Deposit Takers must implement Know Your Customer (KYC) procedures to verify depositor identities and comply with Anti-Money Laundering (AML) regulations.
• Deposit Processing and Reconciliation: NBDT Institutions should have robust systems for secure deposit transaction processing, accurate record-keeping, and reconciliation of deposit activity with internal ledgers.
• Deposit Interest Calculation and Payment: Non-Bank Deposit Takers must ensure accurate systems are in place to calculate interest earned on deposits and ensure timely payment of interest to depositors.
• Deposit Withdrawal Processing: NBDT Businesses should have clear procedures for handling deposit withdrawals, including verification of requests, authorisation processes, and ensuring sufficient liquidity to meet withdrawal demands.
• Anti-Fraud Measures: Non-Bank Deposit Institutions must have robust controls to detect and prevent fraud in deposit and lending transactions, especially important in digital-first or fintech-oriented NBDTs.
• Dormant Account Management: NBDT Institutions should have processes in place for identifying and managing dormant deposit accounts (with no activity for an extended period) to comply with regulations and ensure proper handling of such accounts.

 

Licensing Solutions for Non-Bank Deposit Takers

• Financial Licensing Application Support: We provide comprehensive support for a wide range of non-bank deposit taker licensing applications, including:

• ADI Licence in Australia: We assist non-bank financial institutions in obtaining an Authorised Deposit-taking Institution (ADI) licence from APRA, ensuring compliance with the Banking Act 1959 and other relevant regulations.
• Non-Bank Deposit Takers Licence in New Zealand: Leverage our expertise in navigating the application process and meeting the Reserve Bank of New Zealand's (RBNZ) licensing criteria under the Deposit Takers Act 2023, the Non-bank Deposit Takers Act 2013, and the Banking (Prudential Supervision) Act 1989.
• Building Society Authorisation in the UK: We assist with obtaining the necessary Building Society Authorisation from the Prudential Regulation Authority (PRA), ensuring compliance with the Building Societies Act 1986 and relevant AML regulations.
• Savings and Loan Associations Charter in the US: Our team assists you in navigating the regulatory requirements and obtaining the charter from the Office of the Comptroller of the Currency (OCC) under the Home Owners' Loan Act.
• Capital Markets Services (CMS) Licence in Singapore: We assist you with obtaining a CMS Licence from the Monetary Authority of Singapore (MAS) under the Securities and Futures Act (SFA).
• Class B or Class C Banks in the Cayman Islands: Benefit from our tailored guidance for obtaining a non-bank deposit taker licence for Class B or Class C Banks regulated by the Cayman Islands Monetary Authority (CIMA) under the Banks and Trust Companies Law.
• Non-Bank Financial Institutions in Bermuda: Leverage our expertise to navigate the Bermuda regulatory environment for non-bank deposit takers. We assist with the entire licensing process under the Banks and Deposit Companies Act 1999 by the Bermuda Monetary Authority (BMA).
• Non-Bank Financial Institutions in the BVI: We offer comprehensive support for securing a non-bank deposit taker licence in the BVI. This includes guidance on meeting the requirements set forth by the BVI Financial Services Commission under the Banks and Trust Companies Act 1990.
• Other jurisdictions.

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

 

Policies and Procedures for NBDT Compliance Management

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective NBDT compliance management.
• Effective Procedures for NBDT 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 non-bank deposit takers' 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
• Margin Account Negative Balance Write-Off Procedures
• 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
• 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 Policies
• Staff Dealing and Insider Trading Policies
• Deposit Interest Rate Policy and Procedures
• Fair Lending Policies

 

AML/CFT and Financial Crime Compliance

• AML/CFT Compliance Programs
• AML/CFT Risk Assessment
• Whistleblowing Policies
• 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 non-bank deposit takers 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 prudential regulations, applying NBDT 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 non-bank deposit takers’ licensing requirements and prudential 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 non-bank deposit takers. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented non-bank deposit takers’ compliance, capacity planning, and resource allocation, covering:

• Prudential 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.
• Non-bank deposit takers' 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.

 

Non-Bank Deposit Takers and AML/CTF obligations

We offer a complete set of solutions covering non-bank deposit takers’ 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 non-bank deposit takers’ specific ML/TF red flags and your business specifications
• AML advisory covering financial advice providers' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for non-bank deposit takers
• Internal and statutory AML/CFT audit solutions for non-bank deposit takers
• Financial crime prevention framework development focusing on common fraud risks faced by non-bank deposit takers
• For more information, please visit our specialised NBDT AML Compliance Solutions page

 

Non-Bank Deposit Takers’ Compliance Technology Integration

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

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable non-bank deposit takers’ 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 non-bank deposit takers’ 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 prudential regulations

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting non-bank deposit takers 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 non-bank deposit takers’ compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  Prudential 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 Non-Bank Deposit Takers’ 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 non-bank deposit takers’ 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 NBDT 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 non-bank deposit takers through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.