Fintech Advisor
Strategic frameworks for fintech founders, operators, and product leaders. Knowledge-heavy by design — the right answer in fintech is usually a regulatory and economic judgment, not a calculation.
Disclaimer: This skill provides frameworks and orientation. It is not legal, regulatory, securities, tax, or investment advice. Every fintech business needs licensed legal counsel. Use this skill to organize internal thinking; engage specialist counsel for binding decisions.
Table of Contents
Keywords
fintech, payments, banking, neobank, lending, money transmitter, KYC, AML, PSD2, open banking, BaaS, banking-as-a-service, embedded finance, card issuing, ACH, SEPA, stablecoin, crypto, broker-dealer, RIA, regulation, compliance
Quick Start
Initial Regulatory Triage in 10 Minutes
- Write a 1-paragraph description of what your fintech does (who pays whom, in what form, who holds the funds)
- Run
python scripts/regulatory_trigger_checker.py business_description.txt
- Use the output as input to a conversation with a fintech-licensed lawyer — never as the conclusion
License vs. Partner Decision
- Read
references/license_vs_partner_playbook.md
- For each capability you need (hold funds, issue cards, originate loans, send payments), decide: get a license, or partner with a licensed entity (BaaS, sponsor bank)
- Most early-stage fintechs partner. License only if the unit economics or moat absolutely require it.
Core Workflows
Workflow 1: Regulatory Exposure Scoping
Goal: Understand which US / EU regulatory regimes a proposed fintech business model triggers, before committing to architecture.
Steps:
- Write a clear business description: who pays whom, what is held by whom, where the entity operates
- Run the trigger checker for a quick orientation
- Map each trigger to the relevant regulator (FinCEN, OCC, state banking commissioners, SEC, CFPB, FCA, BaFin, ACPR)
- Engage specialist counsel before designing infrastructure
- Document the regulatory architecture as part of the company's compliance file
Time Estimate: 4-8 weeks of legal scoping for a meaningful new build.
Workflow 2: License vs. Partner
Goal: Decide whether to get the regulated capability yourself, or buy it from a partner.
Steps:
- List capabilities needed: KYC/identity, custody, issuing, acquiring, lending, FX, deposit-taking
- For each, score on the 4-axis grid in
license_vs_partner_playbook.md: cost, time, control, economics
- Pick partners only where the regulator-of-record relationship can survive partner failure
- Document fallback plans if the partner is ever rate-limited, deprecates, or fails
Time Estimate: 6-12 weeks for major capability decisions.
Workflow 3: KYC/AML Program Design
Goal: Build a KYC/AML program that satisfies regulators and doesn't kill conversion.
Steps:
- Read
references/kyc_aml_basics.md
- Design tiered KYC: minimal at signup, enhanced when usage patterns trigger thresholds
- Pick risk-scoring vendor (Alloy, Sardine, Persona, Onfido) and write integration plan
- Establish ongoing monitoring: transaction monitoring rules, periodic refresh, sanctions / PEP screening
- Engage MLRO (Money Laundering Reporting Officer) before going live
Time Estimate: 8-16 weeks for first-time program design.
Tools
regulatory_trigger_checker.py
Scans a business description for keywords and patterns that map to regulatory regimes in the US and EU. Output is a list of candidate triggers, not a legal opinion.
python scripts/regulatory_trigger_checker.py business_description.txt
python scripts/regulatory_trigger_checker.py business_description.txt --json
Triggers detected:
- Money transmission (state-by-state US, e-money/payment institution EU)
- Lending (CFPB, state lending licenses, EU consumer credit)
- Securities (SEC broker-dealer, RIA, EU MiFID)
- Banking / deposit-taking (OCC, FDIC, EU credit institution)
- Payment services (PSD2 in EU, FCA in UK)
- Cryptocurrency (FinCEN MSB, NYDFS BitLicense, MiCA in EU)
- Custody of customer assets
Reference Guides
references/regulatory_landscape.md — Map of US and EU fintech regulators, what each covers, common trigger patterns
references/license_vs_partner_playbook.md — When to get a license, when to partner, partner failure planning
references/kyc_aml_basics.md — KYC tiers, risk-based monitoring, MLRO role, common pitfalls
references/embedded_finance_patterns.md — BaaS architecture, distribution-led fintech, B2B2C patterns
Templates
assets/regulatory_architecture_template.md — Document template for capturing regulatory decisions and partner choices
Best Practices
- Engage fintech-specialist counsel from day one. General-purpose corporate lawyers will miss regulatory triggers. The cost of specialist counsel up front is a fraction of the cost of a regulatory mistake.
- Don't hide behind partners. Even with a BaaS provider, your customers see your brand and the regulator may look through to you. Plan for partner failure.
- State-by-state US is real. Money transmitter laws are state-level — 49 different licenses possible. Most fintechs partner to avoid this.
- Sanctions are absolute. A $100 OFAC violation can cost $10M. Sanctions screening is non-negotiable.
- Treat compliance as product. Frictionless KYC and clear customer comms about why you're asking for documents are a competitive advantage.
Integration Points
- Pairs with
c-level-advisor/cs-fundraising-advisor — investors expect a clear regulatory architecture
- Pairs with
engineering/cs-security-engineer — fintech security goes beyond standard SaaS
- Pairs with
legal/ skills for contract / partner agreements
- Pairs with
business-growth/pricing-strategy — fintech pricing has unusual constraints (interchange, FX spread, float)
1---
2name: fintech-advisor
3description: >
4 Strategic advisory for fintech founders on US/EU regulatory triggers,
5 license-vs-partner, KYC/AML, and embedded finance. Use when scoping a fintech idea
6 or regulatory exposure, or mentioning fintech, money transmitter, neobank, KYC,
7 or PSD2.
8license: MIT + Commons Clause
9metadata:
10 version: 1.0.0
11 author: borghei
12 category: vertical-advisors
13 domain: fintech
14 updated: 2026-05-04
15 python-tools: regulatory_trigger_checker.py
16 tech-stack: fintech, banking, payments
17---
18
19# Fintech Advisor
20
21Strategic frameworks for fintech founders, operators, and product leaders. Knowledge-heavy by design — the right answer in fintech is usually a regulatory and economic judgment, not a calculation.
22
23> **Disclaimer:** This skill provides frameworks and orientation. It is **not** legal, regulatory, securities, tax, or investment advice. Every fintech business needs licensed legal counsel. Use this skill to organize internal thinking; engage specialist counsel for binding decisions.
24
25---
26
27## Table of Contents
28
29- [Keywords](#keywords)
30- [Quick Start](#quick-start)
31- [Core Workflows](#core-workflows)
32- [Tools](#tools)
33- [Reference Guides](#reference-guides)
34- [Templates](#templates)
35- [Best Practices](#best-practices)
36
37---
38
39## Keywords
40
41fintech, payments, banking, neobank, lending, money transmitter, KYC, AML, PSD2, open banking, BaaS, banking-as-a-service, embedded finance, card issuing, ACH, SEPA, stablecoin, crypto, broker-dealer, RIA, regulation, compliance
42
43---
44
45## Quick Start
46
47### Initial Regulatory Triage in 10 Minutes
48
491. Write a 1-paragraph description of what your fintech does (who pays whom, in what form, who holds the funds)
502. Run `python scripts/regulatory_trigger_checker.py business_description.txt`
513. Use the output as input to a conversation with a fintech-licensed lawyer — never as the conclusion
52
53### License vs. Partner Decision
54
551. Read `references/license_vs_partner_playbook.md`
562. For each capability you need (hold funds, issue cards, originate loans, send payments), decide: get a license, or partner with a licensed entity (BaaS, sponsor bank)
573. Most early-stage fintechs partner. License only if the unit economics or moat absolutely require it.
58
59---
60
61## Core Workflows
62
63### Workflow 1: Regulatory Exposure Scoping
64
65**Goal:** Understand which US / EU regulatory regimes a proposed fintech business model triggers, before committing to architecture.
66
67**Steps:**
681. Write a clear business description: who pays whom, what is held by whom, where the entity operates
692. Run the trigger checker for a quick orientation
703. Map each trigger to the relevant regulator (FinCEN, OCC, state banking commissioners, SEC, CFPB, FCA, BaFin, ACPR)
714. Engage specialist counsel before designing infrastructure
725. Document the regulatory architecture as part of the company's compliance file
73
74**Time Estimate:** 4-8 weeks of legal scoping for a meaningful new build.
75
76### Workflow 2: License vs. Partner
77
78**Goal:** Decide whether to get the regulated capability yourself, or buy it from a partner.
79
80**Steps:**
811. List capabilities needed: KYC/identity, custody, issuing, acquiring, lending, FX, deposit-taking
822. For each, score on the 4-axis grid in `license_vs_partner_playbook.md`: cost, time, control, economics
833. Pick partners only where the regulator-of-record relationship can survive partner failure
844. Document fallback plans if the partner is ever rate-limited, deprecates, or fails
85
86**Time Estimate:** 6-12 weeks for major capability decisions.
87
88### Workflow 3: KYC/AML Program Design
89
90**Goal:** Build a KYC/AML program that satisfies regulators *and* doesn't kill conversion.
91
92**Steps:**
931. Read `references/kyc_aml_basics.md`
942. Design tiered KYC: minimal at signup, enhanced when usage patterns trigger thresholds
953. Pick risk-scoring vendor (Alloy, Sardine, Persona, Onfido) and write integration plan
964. Establish ongoing monitoring: transaction monitoring rules, periodic refresh, sanctions / PEP screening
975. Engage MLRO (Money Laundering Reporting Officer) before going live
98
99**Time Estimate:** 8-16 weeks for first-time program design.
100
101---
102
103## Tools
104
105### regulatory_trigger_checker.py
106
107Scans a business description for keywords and patterns that map to regulatory regimes in the US and EU. Output is a list of candidate triggers, **not** a legal opinion.
108
109```bash
110python scripts/regulatory_trigger_checker.py business_description.txt
111python scripts/regulatory_trigger_checker.py business_description.txt --json
112```
113
114**Triggers detected:**
115- Money transmission (state-by-state US, e-money/payment institution EU)
116- Lending (CFPB, state lending licenses, EU consumer credit)
117- Securities (SEC broker-dealer, RIA, EU MiFID)
118- Banking / deposit-taking (OCC, FDIC, EU credit institution)
119- Payment services (PSD2 in EU, FCA in UK)
120- Cryptocurrency (FinCEN MSB, NYDFS BitLicense, MiCA in EU)
121- Custody of customer assets
122
123---
124
125## Reference Guides
126
127- **`references/regulatory_landscape.md`** — Map of US and EU fintech regulators, what each covers, common trigger patterns
128- **`references/license_vs_partner_playbook.md`** — When to get a license, when to partner, partner failure planning
129- **`references/kyc_aml_basics.md`** — KYC tiers, risk-based monitoring, MLRO role, common pitfalls
130- **`references/embedded_finance_patterns.md`** — BaaS architecture, distribution-led fintech, B2B2C patterns
131
132---
133
134## Templates
135
136- **`assets/regulatory_architecture_template.md`** — Document template for capturing regulatory decisions and partner choices
137
138---
139
140## Best Practices
141
142- **Engage fintech-specialist counsel from day one.** General-purpose corporate lawyers will miss regulatory triggers. The cost of specialist counsel up front is a fraction of the cost of a regulatory mistake.
143- **Don't hide behind partners.** Even with a BaaS provider, your customers see *your* brand and the regulator may look through to you. Plan for partner failure.
144- **State-by-state US is real.** Money transmitter laws are state-level — 49 different licenses possible. Most fintechs partner to avoid this.
145- **Sanctions are absolute.** A $100 OFAC violation can cost $10M. Sanctions screening is non-negotiable.
146- **Treat compliance as product.** Frictionless KYC and clear customer comms about why you're asking for documents are a competitive advantage.
147
148---
149
150## Integration Points
151
152- Pairs with `c-level-advisor/cs-fundraising-advisor` — investors expect a clear regulatory architecture
153- Pairs with `engineering/cs-security-engineer` — fintech security goes beyond standard SaaS
154- Pairs with `legal/` skills for contract / partner agreements
155- Pairs with `business-growth/pricing-strategy` — fintech pricing has unusual constraints (interchange, FX spread, float)