FINTRAIL supports digital payments firm to compliantly offer its services to high-risk customers.
Context
FINTRAIL was engaged by a major European digital payment firm, seeking support with its expansion into new high-risk customer verticals, which included gaming and digital currencies.
Solution
We provided recommendations on the client’s bespoke policy documents for the specialist customer segments, based on a proportionate and effective approach to AFC controls for these verticals.
We also created a typologies library for the verticals, identifying the key financial crime risks and recommending a set of transaction monitoring controls mapped against those risks.
Finally, we created bespoke onboarding questionnaires for merchants operating in the target high-risk verticals, allowing the client to tailor its onboarding process to the inherent risks faced.
Outcome
The client was able to move forward with its plans to start offering services to customers in the high-risk verticals, with the compliance team seen as a positive enabler of business growth and expansion.
The compliance team were sure they had understood the risks and nuances of engaging with these new customer segments and had the appropriate policies and controls in place to manage the associated risks.
The client’s control framework relating to these high-risk verticals was clearly documented and explained, enabling them to feel confident discussing with regulators and banking partners why they were confident in taking on this high risk business.
Why FINTRAIL?
FINTRAIL’s breadth of work with leading financial innovators is unparalleled. We have assisted some of the world's most innovative financial service providers operating across six continents to develop and accelerate new products to market and address complex compliance challenges.
We engage in complex compliance challenges within multinational firms that require assessments across multiple business lines and widespread geographic locations, within the context of different operating models, cultural and language diversity, and varying laws and business practices.
We design nuanced, bespoke programmes based on each client’s specific offerings, customer base, and risk profiles to avoid overly simple solutions or generalisations, and we challenge conventional wisdom to identify meaningful ways to assess risk and design effective processes.