For the people behind compliance
Accountable workflows for regulatory reporting, risk methodology and customer risk assessment. Built to keep your team ready for audits, regulatory reviews and the next deadline.
Filing deadlines and methodology drift create different kinds of pressure. Each product focuses on one workflow and makes the work easier to run, review, and defend.
FATCA / CRS / DAC8
Fully managed regulatory filing. We handle XML generation, schema validation, and DIP submission as a Datensender, and deliver your official BZSt receipt.
Risk Methodology & Reg Monitoring
Coming soon
Your risk methodology is generated directly from the live model. When a factor weight changes, the document updates itself. When a new BaFin circular drops, AI identifies which chapters are affected.
What you bought
Risk ratings and methodology that stay aligned as regulations change. Customer and UBO evidence that supports the decision. FATCA/CRS records ready for filing.
What you’re left with
Reconciling risk-engine rules, Word documents and regulatory updates. Chasing UBO evidence and approvals. Rebuilding FATCA/CRS files from exports.
When context, rationale, and evidence stay connected, compliance stops operating in scramble mode. Your team can see what changed, explain why it changed, and answer under pressure without reconstructing the work from scratch.
Linked sources & materials
Rationale & context
Reviews, approvals & sign-offs
Impacts & dependencies
The fines below appear to be about late filings, but the underlying cause is consistently structural. Risk ratings did not hold under scrutiny, triage and investigation ran slower than the filing deadline, and compliance was being run as overhead rather than as a product with domain focus and customer obsession. The same pattern is documented across BaFin, FCA, FinCEN, MAS, and FINMA enforcement in our whitepaper, and it is the gap our products are built to address.
€45M
J.P. Morgan SE
BaFin's largest fine to date, issued for late STR filings between October 2021 and September 2022. The triage and investigation pipeline was running slower than the filing deadline.
€9.2M
N26 Bank
Second BaFin fine after the 2021 action, with a growth cap and a special representative through end-2024. Compliance was being run as overhead, without the product management, customer obsession, and domain focus the work requires.
€6.5M
Solaris SE
Late filings across a banking-as-a-service partner base, which led to the appointment of a special monitor. The risk ratings could not be trusted at the partner level.
We believe your technology should defend you during an audit, not be one more thing you have to defend.
In twenty years of AML, the test was never whether I could block risk. It was whether I could stay defensible to an examiner without turning away the customers the business exists to serve. Staying customer-centric and audit-ready at once: that is the balance.
That is why we stay close to the customer and the people who do the work. It is the only way to build a workflow that works in production and holds up under audit pressure.
Handling billions in payments at scale taught me that security and correctness are not features; they are the foundation. We do not build black-box compliance tools. We build verifiable workflows where the decision, the evidence, and the audit trail stay connected.
That is the engineering discipline we were trained in. It is also what most compliance systems lack. We build ours the other way: auditable by design, from the day they go live.
Research
Whitepapers from 20+ years of compliance operations at Citi, BNP Paribas, and Akbank AG.
BaFin's Proactive Mandate: The KYC/AML Blueprint for German Banks
A Whitepaper on how German Banks can redefine onboarding, KYC/AML, and Fraud handling under BaFin's tougher standards of compliance.
The Missing Methodology Layer
Why the brain of compliance is absent from most financial institutions, and what happens when regulators come looking for it.
The FATCA, CRS and DAC8 Filing Gap
What German financial institutions and crypto-asset service providers actually need to do before the next reporting cycle.
Let's talk
Bring your workflow and your questions; we'll help you understand the fit.
