Anonymised senior review of a financial institution licensing application
License & establishment

Financial Institution Licensing & Establishment

We treat licensing as institution design: aligning the business model, governance, operations, technology environment and control framework behind the application.

Payment & e-moneyBanks & digital banksLeasing · factoring · financeCapital marketsDigital asset servicesNew permissions
Institution design

The regulator evaluates the operating institution behind the application pack.

The revenue model, fund flows, financial projections, governance bodies, control functions, AML/KYC, information systems, outsourcing and continuity arrangements should tell one coherent story.

Scope

Connected building blocks of authorisation readiness.

01

Regulatory perimeter

Clarify regulated activities, permission options, restrictions and critical decisions.

  • Product and service scope
  • Fund and transaction flows
  • Jurisdiction and regulator
02

Business and financial plan

Connect market, customers, revenue, volumes, organisation, investment and capacity assumptions.

  • Scenario modelling
  • Capital and liquidity
  • Break-even and funding
03

Governance and organisation

Design board, committee, management, risk, compliance, control and audit responsibilities.

  • Organisation and RACI
  • Segregation of duties
  • Governance reporting
04

Operations and controls

Build end-to-end processes and controls from onboarding and transactions to complaints and reconciliation.

  • Processes and procedures
  • Control matrix
  • Operational readiness
05

AML/KYC readiness

Connect customer acceptance, risk rating, EDD, sanctions, monitoring and reporting to systems.

  • Compliance programme
  • KYC/KYB journeys
  • Scenarios and cases
06

Technology and resilience

Assess architecture, security, access, logs, change, outsourcing, BC/DR and audit trail readiness.

  • Critical system map
  • IT policies and controls
  • Independent audit readiness
Application flow

From scope to operational permission.

1ScopeBusiness model, permission, jurisdiction and regulatory expectations.
2DesignPlan, governance, process, technology and controls.
3ValidateReadiness review, consistency checks and gap closure.
4Apply & operationaliseApplication, Q&A, inspection and launch readiness.
Regulatory perspective

Every statement in the application needs an operating counterpart.

Roles in the organisation chart, responsibilities in procedures, permissions in systems and management reports should support the same control model.

01Model mismatchThe commercial plan and requested permission describe different activities.
02Late IT involvementInformation systems requirements are addressed only after product design.
03Template documentationPolicies do not reflect the real organisation, systems or outsourcing model.
Application consistency modelAuthorisation readiness requires six domains to describe the same operating institution.
LICENSEreadinessBusiness modelGovernanceOperationsTechnologyAML & controlsFinancial plan
Typical deliverables

What the institution needs to apply, answer and launch.

Regulatory Scope & Licensing AssessmentBusiness model, licensing options, constraints and decision memo.
Business Plan & Financial ModelMarket, revenue, volume, cost, workforce, investment and scenarios.
Governance & Operating ModelOrganisation, committees, RACI, processes, controls and reporting.
Application & Readiness PackApplication, policy library, IT/AML readiness, Q&A and launch plan.