Safeguarding breaks do not clear
Bank, processor and customer-ledger balances are compared in separate files. Unexplained differences roll forward, cut-off is inconsistent, and nobody owns the ageing or resolution of each break.
FinTech and payments
Finance and controls for FinTech that regulators can trace
We work with licensed and pre-licence payment businesses, lending platforms and regulated technology teams that need finance, safeguarding, product economics and governance to survive regulatory review, investor diligence and rapid scale without losing control of customer funds, capital or cash.
What breaks in FinTech
A payment product can look healthy in the management dashboard while the regulated entity is losing control underneath it. These are the points where finance, operations and the licence perimeter stop agreeing.
Own funds become a backward-looking calculation
The regulatory capital calculation is prepared for a return but is not connected to forecast volume, losses, hiring or the board cash plan. A product decision can therefore create a capital shortfall before management sees it.
Payment flows are mistaken for revenue
Customer funds, interchange, scheme fees, processor fees, FX spread and chargebacks pass through the same data model. IFRS 15 performance obligations and principal-versus-agent conclusions are not documented, so gross revenue and take rate cannot be defended.
Credit loss recognition lags the book
A lending portfolio grows faster than its IFRS 9 expected-credit-loss model. Product, vintage, arrears and recovery data do not reconcile to the general ledger, which leaves impairment dependent on manual judgement at close.
Where we help
The work is organised around the decision or control failure, then linked to the finance, risk, strategy and technology workstreams required to fix it.
Safeguarding control design
Define the reconciliation perimeter, data sources, cut-off, exception categories, review evidence and escalation path for customer funds across banks, processors and internal ledgers.
Review the serviceRegulatory finance and own-funds planning
Connect regulatory capital, liquidity, volume and downside cases to the management forecast, with an assumptions register and traceable source data.
Review the servicePayment revenue accounting
Document IFRS 15 policies for fees, interchange, FX and payment flows, including performance obligations, variable consideration and gross-versus-net presentation.
Review the serviceProduct and corridor economics
Build contribution margin by product, customer cohort, channel and corridor, separating take rate, processor and scheme costs, chargebacks, fraud losses, support and cost of funds.
Review the serviceIFRS 9 credit-loss modelling
Tie portfolio segmentation, staging or the relevant simplified approach, probability-weighted assumptions and recoveries back to source systems and accounting balances.
Review the serviceThe technical ground we cover
The exact perimeter depends on the licence, products and home-state supervisor. We work from the rules in force for the relevant entity and keep legal interpretations with authorised counsel.
Licence perimeter and regulatory change
We distinguish the economics and control obligations of an Electronic Money Institution, Payment Institution, AISP and PISP, and include a CASP under MiCA only where the product set requires it. PSD2 remains the operating baseline until the applicable PSD3 and PSR transition changes that baseline. EMI, PI, AISP, PISP, CASP, MiCA, PSD2, PSD3, PSR.
Safeguarding, own funds and wind-down
We map the safeguarding method, customer-funds perimeter, segregation or permitted alternative, daily reconciliation evidence, break management and release rules. The same model connects own funds, regulatory capital, liquidity and the funded actions in a wind-down plan. safeguarding, daily safeguarding reconciliation, own funds, regulatory capital, wind-down plan.
Operational resilience and outsourcing
DORA work covers ICT risk ownership, incident information, resilience testing evidence and the register of ICT third-party arrangements. EBA outsourcing concepts remain relevant to the governance of outsourced functions; the control matrix records responsibilities, access, monitoring and exit dependencies. DORA, ICT third-party risk, ICT incident, resilience testing, EBA outsourcing guidelines, exit plan.
Financial instruments and credit loss
IFRS 9 applies to lending books and other financial assets within scope. We connect expected credit loss to product terms, arrears, migration, recoveries and forward-looking scenarios, and document the approach used for trade or settlement receivables. IFRS 9, expected credit loss, ECL, staging, lifetime expected losses.
What you receive
The output is a working control and reporting system, not a slide deck. The final scope names the artefacts, owners, source systems and acceptance tests.
Safeguarding reconciliation pack
Daily workbook or system specification, source-to-ledger map, exception taxonomy, ageing log, sign-off record and escalation thresholds.
Own-funds and liquidity model
Current calculation, rolling forecast, downside cases, assumptions register and board-level headroom view.
Regulatory reporting lineage map
Field dictionary, transformation logic, reconciliation points, manual adjustments, evidence owners and submission calendar.
IFRS 9 expected-credit-loss model
Model file, source-data specification, segment or stage bridge, assumptions, overlays, controls and accounting memorandum.
How the engagement runs
The engagement begins with one decision or control outcome. We agree the evidence required, build with the people who will operate the process, test it against real data and transfer the working files and ownership to the client.
Confirm the regulated entities, licence perimeter, products, currencies, banks, processors and reporting dates in scope.
You receive the editable models, reconciliations, accounting papers, process maps, control matrix, data dictionary and operating instructions created for the scope. The close-out review records owners, open actions, review dates and any dependency that still requires legal, compliance, tax or audit input.
Diagnose
Establish the facts, quantify breaks and identify the control or decision that fails first.
Design
Agree the target data flow, accounting logic, control evidence, decision rights and implementation sequence.
Build
Create the models, reconciliations, policies and reporting artefacts; run them on live client data and resolve exceptions.
From C-level decision to a working process
U.Avero works with C-level teams to turn critical decisions into operating practice. We combine senior advisory with hands-on implementation, process automation and clearly scoped BPO. Depending on the need, we transfer a working process to the client team or continue to run the agreed scope with clear ownership and controls.
Frequently asked questions
What to clarify before the work starts
Can you work with us before a licence is granted?
Yes. The work can connect the licence business plan to staffing, outsourcing, safeguarding, own funds, liquidity and wind-down assumptions before operations start. Legal counsel remains responsible for perimeter and application advice; we build and test the financial and operating evidence.
Do you replace our compliance team, legal counsel or statutory auditor?
No. U.Avero works on finance, controls, data lineage and operating evidence. Compliance owns regulatory interpretation and monitoring, counsel owns legal advice, and the auditor remains independent. We make the interfaces explicit so the same fact is not represented differently across teams.
Can you reconcile transaction data when the product ledger does not match the general ledger?
Yes, where the required source records and identifiers exist. We define the event model, trace authorisation through settlement and accounting, classify breaks, and establish the adjustments and ownership needed for repeatable reconciliation. Missing evidence is recorded as a limitation, not replaced with an assumption.
Which control should a scaling EMI fix first?
The answer follows the evidence. Safeguarding reconciliation, unresolved customer-money breaks, own-funds headroom and cash runway are tested early because failure can constrain operations. The diagnostic ranks issues by regulatory exposure, cash effect, decision deadline and dependency on other work.
Three commitment levels
Next step
Bring the decision, process or operating gap.
We can start with C-level advisory, implementation, automation or a defined BPO process. We normally aim to reply within one business day. Sensitive detail can wait until an NDA is signed.