When Using Compliance Templates Is Not Enough

When Using Compliance Templates Is Not Enough

Most FinTech founders and experienced executives share with me that?using my templates and workshop materials has saved them a ton of time on research and choosing between various options. They typically look at any template from a common sense perspective, delete or change what does not apply to them, and are happy to submit?and use a version of the document that is "decent".?For them, done is better than perfect.

However, there are situations when templates cannot help you directly. It typically happens when regulators or financial partners ask you about something and you are not exactly sure, what it means, how long your answer should be, or whether you have this process at all. When such ambiguous requests are received by?mid-level compliance experts who are relatively new to their role and don't have help, they may feel uncertain or insecure and overthink everything because they feel they need to be precise and correct 100% of the time.

The most common scenario where templates cannot help directly is when you need to put together an answer or a new policy from a few existing documents, but you don't know what the exact content should be.

Examples:

  • Risk appetite description or a "Risk Appetite statement".?This is not a standard required document, which is why most FinTechs don't have it as a stand-alone form, however, if you think about it – you do have statements about your risk appetite in other documents. For example, you have a list of acceptable and not acceptable countries, you have the service terms where you state who cannot use your services, and you only support a few payment methods or only a few coins. It takes experience to recognize that all those various statements can be put together and form your Risk Appetite statement.
  • Describe your internal assurance processes. Same story, your internal controls are already described in your AML, Risk, InfoSec, and other policies. It is just a question of structuring a new document based on the content you already have.
  • GDPR compliance policy.?This is an interesting one. Technically, you already have your privacy policy. I would say, if someone needs your GDPR compliance policy, it is a question of describing the provisions of your privacy policy, outsourcing policy (with respect to data access and data sharing, etc), GDPR risk assessment, and data retention provisions (which is normally part of the AML policy).
  • Request to produce a detailed flow of funds and settlement arrangements.
  • Forms, questionnaires, and checklists of your partner that you have to complete (especially when you see a direct question and you know that the expected answer should be "yes" but you feel your honest answer is probably "we don't have it").

Someone with decent compliance knowledge (but not yet super confident) and a risk-averse personality would have a tendency to get stuck in many (or almost all) of these cases, thinking "what if", "I am not sure about this, there are so many nuances" or "I don't actually know what they mean by this"...

If you are pressed for time and don't have the experience within the team to figure out how to satisfy specific requests or if you feel that you have gone already through a number of iterations and are not making progress, then the Compliance That Makes Sense Helpline is your answer.

I have helped dozens of FinTech companies get licensed, close partnerships, expand into new geographies and launch new products.?Now – it's your turn!

My consulting clients pay me anywhere from 100k to 300k EUR a year to work with me.?My templates are tested by?dozens of FinTech professionals and hundreds of participants have joined my workshops and shared raving reviews. I?appreciate how valuable my time and expertise are because I know how to get results for my clients.

But over the last years, I noticed that a lot of regulatory issues could have been avoided and time and money?wouldn't be wasted, only if I had been able to meet with these teams sooner and share what I know.

  • So many FinTech startups spend months and months, struggling?to build their compliance documentation from scratch, Googling and copying random policies and contracts from the internet, or hiring expensive lawyers to draft documents that nobody from the company can read or understand.
  • They believe that it's hard or impossible?to find the right compliance people or that they themselves could do compliance better than anyone else by doing their own research and benchmarking everyone.?
  • They sometimes tell me that?they want to be compliant but find it to be an elusive target, where no matter how much they invest, it's never enough, and it takes forever to get anything approved,?nobody?could?answer their questions about what is the real risk of not doing certain things or why their competitor was able to get away with so little compliance efforts.
  • Many of these startups will never make it to the level where they want to be and run out of funding.

This?is the first and potentially the only solution designed by the compliance expert to empower FinTech founders and teams to build and grow their compliance based on agile "just in time" principles and using a pragmatic risk acceptance approach.

Compliance That Makes Sense cannot be learned at regulatory seminars or from reading laws and circulars. It comes from the practice of working with agile dynamic FinTechs, just like yours, who are pressed for time and have a limited budget.

My ultimate?goal is to elevate the prestige and reputation of compliance as a function by helping as many startups as I can, training and empowering their teams, and showing what's possible to achieve with "just in time" compliance and how affordable it can be.

I will give you the practical tools and resources to reduce the workload of your existing team so that they become more efficient and confident because they no longer need to build everything from scratch and can leverage the case studies of others.?

So, tell me – are you still in?

At this point, you may be asking yourself, if you should continue figuring things out on your own or not.

This is actually the wrong question to ask because every successful?entrepreneur and business owner will tell you that they got where they are because they had mentors, external advisers, and support from more experienced people.

So the more powerful question you should be asking is WHO can support you and WHERE you can find help and continued guidance.?

And as you already know, if you choose nothing... then nothing changes. You can obviously keep the status quo blindly pouring more time and money into compliance without much hope of creating different results or reversing?existing inefficiencies... But why would you put yourself into this position, pursuing a broken strategy, draining your resources, and creating more and more organizational conflicts??

If you are still here and still reading and?thinking whether or not you should invest and if so, who will be responsible for actually following the content?and executing the recommendations... just appoint someone to get started.

This is exactly what you don't need to know or decide right now. Right now you have to make a commitment to building a compliance function that makes sense to you and your business and from now on you can take just one step and one decision at a time?to keep making progress.

So –?

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

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

Tune in to this?Compliance That Makes Sense Podcast?episode ?if you prefer to listen to this content instead of reading. ???

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