We kicked off our first “Rise & Shine” event post-summer talking all things regulation. It was a full house bringing together leading experts to discuss why it must be prioritised in any fintech growth strategy. Read on to hear our expert’s top tips.
Opening Discussion: Revolut’s UK Banking Licence Journey
Chris Hill from Fox Williams and Alison Donnelly from FSCom opened the event with an analysis of Revolut’s path to obtaining its UK banking licence. Chris Hill highlighted the importance of compliance milestones for fintechs looking to expand internationally.
"The journey to a banking licence is not just about compliance—it's about proving that you're ready to grow and take on bigger markets,"
Alison Donnelly elaborated on the need for transparency and robust processes during the regulatory approval process.
"Building strong compliance processes from the outset protects not only your business but your customers too."
Panel Discussion: Understanding Regulatory Expectations and Compliance Essentials
Moderated by Charles Kerrigan of CMS UK, the panel featuring Iain Armstrong from ComplyAdvantage, Neil Makwana from Leaman Crellin, and Alison Donnelly discussed the need for embedding compliance early in the product development process. Charles Kerrigan emphasised that compliance should be seen as an integral part of operations, not just a legal requirement.
"Compliance is not just about ticking boxes; it's about embedding good governance that scales with your business"
Neil Makwana agreed, highlighting that fintechs need to view compliance as an opportunity to improve operational efficiency.
"A robust compliance culture ensures that fintechs can scale while managing risks effectively"
Iain Armstrong added that proactive risk management is critical to staying ahead of regulatory demands.
"Risk management isn't just a back-office function—it's a core part of scaling a fintech responsibly"
Navigating the Licensing Process: Practical Experiences
The event concluded with real-world advice from Gerard Hurley (Bound), Willem Wellinghoff (EcommPay), and John Bratowicz (ClearToken) on navigating the regulatory licensing process. They stressed the importance of strong governance structures and maintaining transparent relationships with regulators.
"Good governance and accountability are non-negotiable when dealing with regulators"
Gerard Hurley emphasised the need for ongoing engagement with regulatory bodies.
"Proactively managing relationships with regulators helps fintechs avoid costly missteps later on"
John Bratowicz from ClearToken shared insights on the complexities of managing compliance across multiple jurisdictions, particularly in the blockchain space.
"Navigating regulatory frameworks across different regions requires meticulous planning and alignment with both local and global standards."
The key takeaway:
Compliance is not just a box-ticking exercise but a strategic asset for fintechs aiming for sustainable, scalable growth.
Our Experts Tips
Chris Hill, Partner, Fox Williams
“Start early with regulators: Early engagement and consistent communication with regulators are essential to streamline the approval process and mitigate potential challenges down the line.”
“Get your business in shape before applying: It’s vital to have robust internal processes, governance, and compliance protocols in place from the outset. Preparing for regulatory approval is not just about getting authorised—it’s about ensuring your business can thrive in a regulated environment.”
“Invest in compliance from day one: Underinvesting in your compliance functions is a mistake. Compliance should be a core part of your growth strategy, not an afterthought. Proper investment ensures you can meet ongoing regulatory requirements as you scale.”
Alison Donnelly, payments regulation specialist and director of the GRC consultancy, fscom
“Regulated status is a prized possession; expect to invest significantly upfront to super-charge your business on the maturity path or collaborate with a regulated partner in the first instance.”
“Regulations and regulatory expectations are not as mysterious as they can at first seem; in the main, they boil down to sensible, thoughtful decisions that put the consumer first.”
“The application is just the paperwork; bring the right people together to take the sensible, thoughtful decisions on how to run your business and the application pack will come together easily”
“Regulators are very clever people, but only human; seek advisors who cut through jargon to precisely and clearly communicate your message.”
Charles Kerrigan, Partner, CMS UK
“Seek out honest and realistic advice. Work with professionals who will give you honest advice about your realistic chances of a successful application. If your odds aren’t high, get advice on how to improve them”
“Explore other revenue-generating options doing business that is not regulated to keep cash flow going while you are on your path to getting regulated.”
“Don’t rush a poor application to “get it on the regulator’s desk” as soon as possible. Provide a complete and high quality set of documents the first time.”
Iain Armstrong, Global Regulatory Affairs Lead, ComplyAdvantage.
With 20+ years in banking and regulation, Iain now supports the development of one of the world’s leading anti-financial crime regtechs.
“Managing risk is everybody’s job: a Compliance team can help to set the guardrails, but the most effective approach to risk management is to have it strongly embedded across your First Line. This means that everyone should have an understanding of the regulatory risks that are inherent to their function in particular, and should be mindful of how they can minimise those risks in the course of delivering in their role.”
“Write and retain! Don’t let your internal instant messaging system (e.g. Slack) be the only place where big decisions are recorded. Always ask yourself: “in three years’ time, if someone wants to know how and why we chose a particular path, would we be able to easily provide an answer, with supporting evidence?”
“Govern for the organisation you want to be, not the one you are today: the bigger and more successful an organisation gets, the more important corporate governance becomes. Embed good practices around ownership, accountability, and decision-making early on. This does not mean boiling the ocean! But it’s easy for important things to slip through the cracks without sufficient oversight.”
Neil Makwana, Principal Compliance Consultant at Leaman Crellin.
With many years of experience spanning UK regulators, banking and digital assets, Neil now leads projects to enhance regulatory compliance and licensing efforts.
“Think about cultural fit. Recruit Compliance teams that have the skills and adaptability to work with Senior Management from unregulated technology backgrounds and convey that compliance can be a driver for business growth.”
“Be very selective about advisors and don’t assume one advisor can do everything. Law firms will be a big help on policies and business plans, but you may need compliance consultants for your firm-wide risk assessments for example.”
“Don’t have your business try and do everything from the outset; be realistic about product ranges and target customer markets. A more focused application will be easier to prepare and can the scope can be expanded once operational.”
Willem Wellinghoff is the Chief Compliance Officer at Ecommpay.
Willem has vast practical experience working with regulators and aims to make compliance human.
“Be Prepared is your key to success! Clearly communicate expectations to investors, your Board and internal teams. Detail in your application to regulators your business’ entire operations, from strategy and processes to controls, governance and risk management. Avoid selling your investment pitch and dream.”
“Regulators are also human. Regulators only get a snapshot view of your business. It’s important you engage early and communicate clearly and transparently. Don’t judge – Regulators have the hard job of understanding and supervising so many different business models.”
“The beauty of the UK is that it is still open for innovation. Regulation is still principles and risk-based. It’s for compliance professionals to humanise those elements to enable business to practically apply it and grow. Think of your compliance as an enabler, not a nay-sayer!”
“Don’t knock the experience. Businesses cannot discount how much value an experienced compliance professional can bring. They don’t come cheap but they sure can add value when working with regulators and help operationalise strong processes and enable strong controls.”
Gerard Hurley, Compliance Director & MLRO, Bound.
Gerard was the first compliance person at leading fintechs, Funding Circle and Chip before leading compliance at Bound. He loves getting new products into customer’s hands.
“Be curious. You’ll make a great compliance leader by being curious and interested in your business. Your company will develop better products when you know more.”
“Team first. Give more of yourself to get things done so that your teammates will trust your advice. Say ‘yes’ a lot by being flexible and helpful and your ‘no’s’ will be rare but respected.”
For those eager to continue the dialogue, join us online at Fintech Fringe Forum where you can access resources and read top tips on support available for fintechs who are scaling.
Join the next Event
The next Rise & Shine event will be on October 03 and will focus on Growth Marketing.
Please contact Calypso Harland, if you would like to be involved.