Design and implement your fintech compliance program with full regulatory assurance: specialist advice on AML/CFT, PSD2, MiCA, DORA and payment services regulation for financial technology companies operating in Spain and the European Union.
“We design the complete fintech compliance program: AML/CFT, PSD2, GDPR, operational risk management and relations with the supervisor for electronic money institutions and payment institutions.”
“We advise collective investment platforms, crowdfunding platforms and robo-advisors on the design of their fintech compliance systems in line with MiFID II, ECSPR and CNMV rules.”
“We implement the fintech compliance framework for crypto-asset service providers: VASP registration, MiCA, the Travel Rule and the AML/CFT obligations specific to the crypto sector.”
“We prepare your fintech for DORA: ICT risk management, business continuity plans, audits of critical providers and a framework for reporting incidents to the supervisor.”
Design and implementation of the anti-money laundering system for fintechs that are obliged entities: risk assessment, manual, KYC procedures, training and a reporting channel to SEPBLAC.
Advice on obtaining a license as a payment institution, electronic money institution or alternative investment fund manager, or VASP registration, with the Bank of Spain, the CNMV or SEPBLAC.
Implementation of the PSD2 compliance framework: strong customer authentication (SCA), management of TPPs, account access agreements and alignment with the EBA RTS for payment fintechs.
Alignment with the MiCA Regulation: token classification, white paper, reserve policies, internal governance, capital requirements and reporting obligations for issuers and CASPs.
ICT risk management framework under DORA: inventory of digital assets, incident management, audit of critical providers and business continuity plan for financial entities.
Independent review of the fintech compliance program: regulatory gap analysis, assessment of controls, findings report and action plan to pass supervisory inspections.
A constantly changing regulatory environment: PSD2, MiCA, DORA, AMLD6 and CNMV/Bank of Spain rules evolve quickly, and fintechs without an up-to-date compliance program build up exposure to penalties without knowing it.
Active supervision and inspections: the Bank of Spain, the CNMV and SEPBLAC have stepped up their inspection activity on fintechs, neobanks and payment platforms. Compliance shortcomings lead to penalties and license revocations.
Money laundering risk: fintechs are one of the sectors with the highest AML/CFT risk, according to FATF and SEPBLAC reports. A weak KYC/AML program can unintentionally turn the platform into a vehicle for money laundering.
Blocked banking and correspondent relationships: banks and payment service providers require their fintech clients to show an adequate level of compliance before opening accounts or establishing correspondent relationships.
A requirement for raising investment: venture capital and private equity funds put the fintech compliance program through due diligence before investing. A weak compliance function can block funding rounds.
Fintech compliance is the set of policies, procedures, controls and systems that a financial technology company puts in place to ensure compliance with the regulatory obligations that apply to its business: anti-money laundering, data protection, payment services, securities markets, crypto-assets and digital resilience.
Unlike a traditional financial institution, a fintech faces a particularly complex regulatory environment: it operates at scale, grows fast, relies on third-party technology and often operates under several regulatory regimes at once (Bank of Spain, CNMV, SEPBLAC, AEPD).
A solid fintech compliance program is not just a legal obligation. It is a competitive advantage that makes it easier to obtain licenses, open bank accounts, raise investment and expand internationally.
The regulatory framework for a fintech in Spain cuts across several areas and depends on the business model. The main rules that apply are: Law 10/2010 on AML/CFT and its implementing Regulation (Royal Decree 304/2014) for obliged entities, PSD2, transposed by Royal Decree-law 19/2018, for payment services, the MiCA Regulation for issuers and crypto-asset service providers, and the DORA Regulation for ICT risk management.
In addition, fintechs that provide investment services or collective portfolio management are subject to MiFID II (transposed in the TRLMV and Royal Decree 217/2008), to the ECSPR Regulation if they operate as a crowdfunding platform, and to the GDPR and the LOPDGDD on personal data protection.
Because several regulatory regimes overlap, fintech compliance requires an integrated approach that covers all obligations in a coordinated way and without duplication.
A complete fintech compliance program brings together several dimensions. The first is the compliance function: appointing the compliance officer and defining their position in the organizational chart, their resources and their access to senior management.
The program must be reviewed and updated regularly to incorporate regulatory changes and lessons learned from supervisory inspections.
Fintechs that provide payment services, currency exchange, crypto-asset management or financial intermediation are obliged entities under Law 10/2010. They must implement an anti-money laundering and counter-terrorist financing system adapted to their digital model.
Digital onboarding is the most critical point of AML/CFT compliance for a fintech: it must be smooth for the user and rigorous for the regulator at the same time.
The DORA Regulation (Digital Operational Resilience Act), applicable since January 2025, sets mandatory digital operational resilience requirements for all financial entities, including fintechs licensed in the EU: ICT risk management, incident reporting, resilience testing and management of the risks from third-party technology providers.
For fintech compliance, DORA means putting in place a formal ICT risk management framework, classifying and auditing critical technology providers (cloud, core banking, APIs), setting up a process to report major incidents to the supervisor and carrying out regular resilience testing (TLPT for significant entities).
Fintechs that rely on cloud infrastructure or third-party technology providers must pay particular attention to the contractual management of these risks and to the subcontracting chain, which DORA regulates in great detail.
One of the most direct uses of fintech compliance is preparing and managing the authorization application before the Bank of Spain, the CNMV or SEPBLAC to obtain the licenses needed to operate: payment institution, electronic money institution, alternative investment fund manager, crowdfunding platform or CASP under MiCA.
The Spanish regulator requires the application to include the program of operations, the internal procedures manual, the risk assessment, the business plan, the internal controls and the fit and proper documentation for the directors. A fintech compliance program that is well built from the outset significantly speeds up the authorization process.
With specialist fintech compliance advice from the business model design stage, you can structure the activity so that it meets regulatory requirements from day one and avoid costly restructuring later.
The cost of implementing a fintech compliance program depends on the size of the company, the business model, the number of licenses required and the regulatory complexity. For an early-stage fintech, the cost of a basic compliance program is significantly lower than that of a fine or the loss of a license.
Options range from one-off advice on specific regulatory questions to an outsourced Compliance Officer service (outsourced CCO), which gives the fintech a complete compliance function without having to hire a senior profile in-house.
Investing in fintech compliance from the start is always more efficient than fixing it after an inspection or a penalty. The cost of not having an adequate program can be exponentially higher in terms of fines, reputational damage and lost business.
Fintech compliance connects with other key areas of regulatory compliance, anti-money laundering, crypto-assets and data protection. Discover the services that complement your program.
Full catalog of anti-money laundering services: risk assessment, manual, training and audits for fintechs that are obliged entities.
MiCA regulatory advice, VASP registration, the Travel Rule and specific compliance for fintechs in the crypto-asset and blockchain sector.
Criminal and corporate compliance programs: whistleblowing channel, code of ethics and internal controls for fintechs with complex corporate structures.
Independent regulatory compliance report: gap analysis, assessment of controls and documentation for supervisors and investors.
Design of the AML/CFT system: digital KYC, beneficial ownership, transaction monitoring and preparation for SEPBLAC inspections.
Mandatory policy document setting out measures, procedures, roles and workflows adapted to the fintech’s digital model under Law 10/2010.
Obtaining registration as a crypto-asset service provider (CASP/VASP) with the Bank of Spain and alignment with the MiCA Regulation.
Criminal compliance program for fintechs: whistleblowing channel, code of ethics, controls and evidence for regulatory inspections.
Check the situations that apply to your company. The more that match, the more urgent it is to have a solid, up-to-date fintech compliance program.
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Check the situations that apply to your fintech.
Everything you need to know to build a robust fintech compliance program: the concept, the regulatory framework in Spain and the EU, the structure of the program, its link with AML/CFT, DORA and MiCA, and the mistakes you should avoid.
Fintech compliance shares the essence of traditional corporate compliance (identifying, managing and mitigating regulatory risks) but operates in a radically different environment: exponential growth, digital onboarding at scale, heavy use of third-party technology, disruptive business models that often move ahead of the regulator, and a global client base that reaches beyond any single jurisdiction.
Because of this, fintech compliance cannot simply be an adaptation of the traditional banking model. It requires an approach designed from scratch for the digital environment: automated processes, integration with the company’s technology systems, the ability to scale with the business and continuous updating in a regulatory framework that keeps evolving.
The fintech regulatory ecosystem in Europe has undergone a deep transformation over the last five years. PSD2 redefined payment services and opened the market to new players. The MiCA Regulation, fully applicable since 2024, created the first harmonized framework for crypto-assets in the EU. The DORA Regulation, in force since January 2025, set digital operational resilience standards for all entities in the financial sector.
In Spain, the Bank of Spain handles the authorization and supervision of payment institutions and electronic money institutions, the CNMV supervises investment and crowdfunding platforms, and SEPBLAC is the Financial Intelligence Unit responsible for supervising AML/CFT compliance. Because several supervisors are involved, fintech compliance in Spain is particularly demanding for business models that span several regulatory categories.
An effective fintech compliance program rests on three pillars. The first is compliance governance: appointing the Chief Compliance Officer (CCO) or compliance officer and defining their position in the organizational chart, their budget, their access to the board of directors and a reporting line that is independent from the business areas.
The second pillar is the framework of policies and procedures: compliance manual, KYC/AML policy, conflicts of interest policy, client protection policy, information security policy and all the operating procedures that allow the organization to meet its regulatory obligations day to day.
The third pillar is the control and monitoring system: screening tools, transaction monitoring, incident log, regular internal audits, ongoing team training and mechanisms for reporting to the supervisor. Without this third pillar, fintech compliance exists only on paper.
Customer identity verification (KYC) is the operational core of fintech compliance in AML/CFT matters. Fintechs face the challenge of carrying out this process fully digitally, at scale and in real time, while meeting both the identification requirements of Law 10/2010 and the EBA technical standards on strong authentication.
eKYC solutions (video identification, document OCR, biometric verification, PEP and sanctions databases) must be integrated into the fintech compliance system so that the results are documented and auditable. The EBA has published specific guidelines on remote customer onboarding that the fintech must build into its procedures.
The beneficial ownership of legal entities remains the most critical point, and the one most often deficient, in fintech compliance programs. Many platforms carry out rigorous KYC on the client company but do not go as far as identifying and verifying the natural person who ultimately controls it.
Crypto fintechs face a particularly demanding compliance framework. The MiCA Regulation requires crypto-asset service providers (CASPs) to obtain authorization in an EU Member State, have a tailored compliance program, publish a white paper for token issuances and meet capital, custody and internal governance requirements.
The Travel Rule, implemented in Spain through Law 10/2010 and FATF guidance, requires CASPs to transmit originator and beneficiary information on crypto-asset transfers above certain thresholds. This requires specific technology solutions and agreements with other platforms to exchange data.
The most common mistake is treating compliance as a documentation exercise: drafting policies and manuals that nobody reads, that are not built into operating processes and that are not updated when the rules change. Fintech compliance on paper protects neither the company nor its managers.
Another common mistake is outsourcing compliance without internal oversight: hiring an external provider to handle KYC or monitoring and assuming the problem is solved, without setting metrics, regular reviews or internal accountability for the results. The regulator holds the entity responsible, not the provider.
Finally, the most costly mistake is failing to anticipate regulatory changes: many fintechs find out that they have to adapt their business model, technology or corporate structure when the rules are already in force, with the costs and delays that this entails. Proactive fintech compliance is always more efficient than reactive compliance.
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