In a extremely regulated {industry} like fintech, constructing a digital product can generally really feel like stacking a home of playing cards. In case your group is unable to answer regulatory modifications rapidly, any modification in rules would possibly transform an issue. How are you going to construct one thing that can stand up to winds of fixed regulatory change? Dennis Overbeeke has the solutions.
The CTO vs Standing Quo collection research how CTOs problem the present state of affairs at their firm to push it towards a brand new top … or to put it aside from doom.
“If there’s one factor that at all times retains me awake, it’s maintaining the Personally Identifiable Data (PII) of our prospects protected”
Being a expertise professional isn’t sufficient if you wish to flourish as a CTO of a highly-regulated firm. Few industries can compete with finance in relation to regulatory complexity, so Dennis Overbeeke is the proper particular person to clarify these challenges.
He’s the CTO of an modern fintech firm within the European Union, a area recognized for its authorized complexity. Throughout our interview, he informed us about:
- how to make sure that your organization can rapidly adapt to new rules,
- when to make use of third-party distributors and easy methods to confirm them,
- the only finest means to consider compliance.
Learn how to show regulatory burdens into enterprise alternatives.
About Dennis & New10
Skilled CTO and senior IT chief within the FinTech area, specializing in constructing and scaling modern startups and scale-ups. No problem is just too large for him: he has pushed the success of digital lending platforms and different cutting-edge options and even taken over CEO tasks when it was obligatory.
Administration, technical course, cybersecurity, agile, group constructing
A subsidiary of ABN AMRO, New10 helps entrepreneurs with straightforward and fast entry to enterprise financing. They make making use of for enterprise financing quick, easy, clear, and customized.
New10’s imaginative and prescient
Arkadiusz Kowalski: Hi there, Dennis. You got fairly a problem this 12 months – for a number of months, you have been the interim CEO of New10 along with your position as CTO. May you inform me extra about this position? Did you might have loads to be taught within the early weeks? Was it sudden? How was it for you?
Dennis Overbeeke: Hello Arek, thanks for having me! It was actually fascinating. Our CEO went on sabbatical and requested me to step in, which was each good and a bit scary.
I’ve at all times been serious about areas outdoors of tech. I like to be part of our administration group discussions, not simply those associated to software program or structure. Monetary objectives, setting the technique, advertising and marketing, danger and rules – all of them have been fascinating matters to me for a very long time.
Nonetheless, the expertise broadened my perspective on the corporate. My understanding was once centered on understanding how expertise contributes to our firm objectives – now, I perceive even higher our financial institution’s perspective on what New10 can contribute in direction of their objectives.
New10 helps corporations safe funding. What are your principal challenges going ahead in 2024 and 2025 on this space – each from a technical and a extra basic perspective?
When New10 was created, the aim was to digitize a really conventional course of. As a director of a small SME firm searching for credit score or a mortgage, you needed to undergo many tedious steps. However now, digitization is a commodity, so we should maintain innovating and determining methods to enhance our buyer expertise.
It may be tough – we wish to assist individuals do issues at scale, however on the similar time we don’t need them to really feel like they’re speaking to a robotic. So whereas we’re making an attempt to innovate and work out easy methods to use new tech like AI, we are able to’t overlook that we’re doing it to make our prospects’ lives simpler.
One other problem is sustaining compliance with all new rules within the monetary {industry}, which by no means ends.

Compliance and rules
I’m glad you talked about compliance. The monetary sector has at all times been extremely regulated, so one may suppose that sustaining compliance is a trivial downside by now. But I’ve learn a report that acknowledged 93% of fintechs wrestle with it. Why do you suppose that’s?
Guidelines and rules from governments, legislative events, or centralized banks often aren’t necessities however pointers that have to be interpreted. So you must interpret the regulation correctly, then work out easy methods to be compliant along with your present expertise setup and – much more importantly – easy methods to keep customer-friendly whereas doing so.
A number of compliance is about gathering extra knowledge. The simple resolution is to burden your prospects with extra questions, consumption kinds, or onboarding steps. Nevertheless, it’s best to intention to resolve it in a better means. And, after all, by the point you’ve discovered what new laws means for your online business, easy methods to remedy it, and what tech to make use of, there’s already one thing new you must handle. So, one other problem right here is that you just’re making an attempt to future-proof your tech so that you just received’t need to do an overhaul subsequent 12 months.
Some banks or fintechs succeed after they see compliance as a chance, not a burden. They search for alternatives to do issues higher than their rivals and even create fully new merchandise, propositions, or enterprise fashions based mostly on new laws.
In a earlier interview we lined TrusTrace, which makes use of AI and blockchain to centralize provide chain knowledge and enhance regulatory compliance. This made me consider using automation for compliance. Some name it a proactive compliance technique versus a reactive one the place corporations manually make modifications to answer new rules. What’s your tackle it?
Automation is a part of the answer, however I feel the extra essential factor is modularity and configurability relatively than pure growth. You’ll be able to’t predict rules forward of time, however there’s often a very long time body when you’ll be able to tag alongside and see the place issues are going. With a modularized system, implementation is less complicated.
When you pre-code each eligibility rule or enterprise rule onerous, you will want to revise all the things when one thing modifications. As an alternative, you can also make a call engine the place you modify guidelines relatively than having to replace your code or platform every time.
What I’m listening to is that your tech ought to be versatile. What are different methods to just be sure you can rapidly implement new compliance necessities down the road?
Early on, you must work out the place in your processes you’ll have these regulatory decision-making factors. Now we have to make choices consistently on every utility, so we attempt to construct engines the place we are able to have these resolution guidelines configured.
It’s a scalable resolution within the sense that whenever you get new guidelines, you simply add them to your present engine relatively than having to construct new sorts of checks and balances every time.
Compliance and development may be seen as opposing forces. However the best way you set it, that we’ve to have a look at them as potential alternatives to maneuver ahead is de facto fascinating.
That is what defines fintech. Many fintech corporations are difficult a really conventional {industry}, and so they use tech to offer trendy methods for fixing consistently altering laws and compliance points.
It may be a neobank saying, “Hey, we don’t have workplaces anymore, so you are able to do all the things from the consolation of your sofa, and it’s all completely safe.” It might be these third events that assist with ID&V. It might be suppliers that may do a whole lot of checks and balances on KYC, or see if prospects are on sanctions lists.
Right this moment, AI is a large alternative for monetary providers however it additionally brings its personal issues. Will all of us remedy them ourselves, or will we’ve new fintechs that present AI in a compliant, safe, and clear means for use within the monetary providers {industry}? Time will inform.
Do you do all of that in-house? Some say that you just shouldn’t outsource your core competencies if you wish to defend your IP. Would you say that compliance is a type of core competences of fintechs right now?
It’s nuanced.
You may outsource sure features of compliance to SaaS options or third events – however it’s you who’s going to be held accountable. You’ll be able to’t outsource accountability. That’s why fintechs or banks choose to maintain that in-house.
There’s additionally the query of expertise and experience. You must resolve whether or not to make one thing, purchase it, or outsource it.
We even have a particular fourth choice – being the subsidiary of a financial institution, we’ve shared capabilities. When we’ve to do one thing new round KYC, decision-making, eligibility guidelines, or danger assessments, we regularly use the talents, experience, and shared capabilities from the financial institution. They’re actually good at it, and that’s why they exist. And after we wish to enhance on the financial institution’s conventional method, we are able to select to construct one thing ourselves.
Coming into new markets
Certainly one of our current company, based mostly within the Netherlands, informed us concerning the challenges of increasing into the German market. They assumed it will be comparatively straightforward given the truth that they have been neighboring nations and each members of the EU. Nevertheless there turned out to be many compliance and culture-related challenges concerned. Do you suppose internationalization is an issue that expertise can remedy within the fintech context?
I’m undecided. Now we have firsthand expertise with cross-border concepts and experiments. Even throughout the EU, every nation implements regulation in another way. For instance, within the Netherlands we do Identification and Verification (ID&V) – we have to know who our prospects are by scanning their passport, taking a selfie, and doing an automatic liveness test. We are able to confirm them remotely.
In Germany ID&V is finished via video identification – you must ‘see’ the particular person on the opposite facet. You’ll be able to nonetheless do it remotely, however it needs to be a videoconference involving actual people. If an organization has mastered enlargement throughout the EU, they most likely have expertise that solves this. So, after we use third-party distributors, we don’t simply have a look at their resolution within the Netherlands, but in addition if it may be transposed to different nations.
Know-how can remedy cross-border issues, however you’ll be able to’t be lazy and anticipate a ready-made, straightforward resolution right here. You must give it some thought loads.
On a world scale, what must change for internationalization to change into simpler sooner or later?
It could be nice to have industry-accepted digital identities that work globally and even simply within the EU. Clients may then simply work with totally different corporations in numerous nations, and also you, as a supplier, would solely want one technique to do ID&V.
Aside from digital identities, standardized and uniform industry-accepted KYC can be nice as nicely. Not simply understanding who the client is, however understanding concerning the firm, understanding their historical past of transactions and corporations they work with.
Growing the variety of internationally accepted regulation requirements and implementations can be an unlimited assist for fintechs that wish to broaden to totally different nations.
AML & KYC
I do know that AML and KYC are notably essential components of compliance technique, as a result of we have to be sure that your purchasers and enterprise companions are reliable. What do you suppose are the largest technological modifications on this space in 2024 and 2025?
AI is the apparent one. Increasingly more knowledge is getting used to make KYC and AML choices. Regulatory and compliance calls for maintain including checks and balances that we have to do because the gatekeepers of economic providers. We have to join extra knowledge sources with extra complicated decision-making, and AI may assist with that. The issue is that we don’t know the way lengthy it’ll take for AI to change into an accepted resolution. It introduces new challenges with hallucinations, trustworthiness, or auditability.
With transaction knowledge, we at all times suppose in chains – one firm makes a transaction with one other, that one goes to a different, and so forth. Corporations have many connections. Some are easy authorized entities, others are a part of a gaggle of consumers, and contain a whole lot of pure individuals that should be recognized. Having a digital means of connecting all of these issues collectively would assist. This might be blockchain or one thing else that ensures you’ll be able to belief knowledge that others have already collected.
That’s the factor concerning the monetary {industry} – we’re all fixing the identical issues. If you wish to change banks, you’ll have to do KYC and AML another time. Proper now, there isn’t any means for a buyer to say, “Financial institution A already verified me, may you utilize their knowledge to confirm me?”
And what about third events? From what I do know, there are some that provide sturdy KYC options. Is it doable to automate the method fully?
Sure, I feel we will automate it fully. Nevertheless, with out standardized worldwide rules, you presently can’t outsource the entire course of to a 3rd occasion. I feel each consumer of a third-party KYC automation resolution would nonetheless wish to have their very own enterprise guidelines and their very own resolution engine.
In observe, the necessity for human intervention right here boils right down to the 80-20 rule. 80% of KYC might be automated, however there are at all times edge circumstances that should be double-checked or re-interpreted by a human.
So, people will at all times be wanted on this course of?
I feel so, sure.
My earlier startup, Blanco, offered a digital onboarding resolution – KYC, ID&V, and buyer profiling. Nevertheless, everybody wished to have the ability to present their very own decision-making within the software. Everybody had a unique mind-set about laws or profiling the danger urge for food of sure prospects.
If distributors wish to get extra prospects right here, I might say that they should permit their prospects to customise the answer.
Knowledge privateness & AI
I’m curious the way you method delicate consumer knowledge. Tech can go a good distance in defending the purchasers of economic establishments and fintechs. What are some threats that you just’re particularly involved about relating to delicate consumer knowledge?
If there’s one factor that at all times retains me awake, it’s safety and maintaining our prospects’ Personally Identifiable Data (PII) protected. We’re compelled to retailer increasingly more data every day.
Prior to now we saved a bit of data in a single system, now we retailer a whole lot of data throughout many programs. Every system wants its personal safety – the fitting knowledge classification, the permission programs, entry management and so forth. And we’re not even speaking about hackers but, simply making an attempt to resolve who ought to have entry to which knowledge.
Then, there are retention insurance policies, with GDPR being a vital piece of laws within the EU. How lengthy do it’s important to retailer your buyer’s knowledge? Are you 100% assured it is going to be wiped as soon as you aren’t allowed to retailer it anymore?
Some corporations go to nice lengths to anonymize consumer knowledge earlier than utilizing OpenAI or different proprietary LLMs. Do you see AI as a possible menace to privateness?
I don’t see AI as a menace to privateness, no less than from my firm’s view. However we want to pay attention to the place we push our knowledge. I feel no person in monetary providers, be it an enormous financial institution, a fintech firm like New10, or a neobank, would say, “Oh yeah, let’s use the general public OpenAI mannequin to run some enterprise choices on our prospects’ knowledge.” I feel we’re all implementing a safe and compliant AI implementation that matches our necessities.
The reason being that everybody is afraid of two issues: that PII will leak to a 3rd occasion and that we would leak sure strategic data to the skin world, and proprietary fashions will practice on it.
Nonetheless, there are a whole lot of doable options with your personal hosted fashions or masking knowledge earlier than sending it.
What are another necessities that third events want to satisfy in the event that they wish to cooperate with a fintech that works on this tightly regulated sector?
It’s totally different for each firm in monetary providers, however I’m 100% certain that each one of them have third-party danger administration. Danger may be very particular to your organization, and everybody has a danger urge for food. Inside that urge for food, you establish the foundations and rules and the necessities to your third-party distributors.
It is perhaps on the tech facet, like what sort of encryptions you’re utilizing, or on the enterprise facet – what sort of processes you might have in place or what subcontractors you might be working with?
There are a whole lot of strict guidelines on third events that we are able to use, however they don’t need to be a blocker. If we wish to use a brand new vendor, we do a Change Danger Evaluation (CRA). Doing a CRA on a 3rd occasion tells you that we’ve necessities for every third-party vendor that we wish to combine or work with.
Innovation
As a result of compliance can take a whole lot of effort, even in the event you do use a whole lot of expertise to realize it, it’s nonetheless a steady wrestle. As a fintech, it might deter you from innovation. So how do you strike a stability to not let the compliance subject maintain you again, however not compromise it both? How you can use knowledge for innovation in a means that’s nonetheless truthful and aggressive?
As I discussed earlier than, we may be most profitable after we see alternatives as a substitute of burdens.
Take the Fee Service Directive (PSD2). I feel a whole lot of banks have been combating it as a result of they needed to open up their programs. Generally, even conventional mainframe programs had to offer APIs in order that third events may acquire transaction knowledge.
However I feel it exhibits that it might additionally assist remedy AML or KYC issues. We use these PSD2 connections in a really client-friendly means. We are saying, “We have to overview your transaction knowledge, we have to know which nations you’re coping with, we have to present a danger profile, we have to do a danger and credit score evaluation. Are you able to present us with all that data?” – however we are able to do it on the click on of a button.
Fintech in a extremely regulated sector – wrapping up
It’s a steady wrestle. To sum issues up and given all we’ve talked about right now, what do you suppose are an important takeaways to recollect for the CTO that faces fintech compliance challenges?
The primary large factor is: don’t see compliance as a burden. It’s a obligatory a part of being a CTO in monetary providers.
Secondly, see how expertise will help you remedy compliance and rules, and attempt to go one step additional – see how guidelines and rules can open up new alternatives and potentialities to use expertise.
Sources
Are you able to share some sources for our readers who wish to be taught extra about regulatory challenges in fintech or normally, one thing that you’d suggest for anybody working as a CTO or tech chief within the fintech {industry}?
I learn a whole lot of books on tech, administration, and enterprise normally. My favourite remains to be Essentialism from Greg McKeown. I learn a whole lot of articles from locations like HBR or Medium and I’m subscribed to some newsletters for inspiration, corresponding to CTO Craft.
In the case of podcasts, I like FinTech Insider, Leaders in Finance, Fashionable CTO. I’m now hooked on a Dutch Podcast on Synthetic Intelligence.
What’s subsequent? 4 priorities for fintech CTOs to uphold
Constructing an organization in a extremely regulated {industry} like fintech requires a novel mindset. Know-how is only one piece of the enterprise puzzle when it’s important to navigate complicated, constantly altering rules and stability them with innovation, development, and buyer expertise.
Listed below are an important concerns for fintech CTOs, in line with Dennis:
- As an alternative of taking a look at it as a burden to cope with, have a look at compliance as a chance to create new merchandise, choices, and even enterprise fashions.
- All the time concentrate on the place you’re pushing your knowledge to keep away from leaking your prospects’ PII and your in-house IP – be notably cautious if you wish to use proprietary LLMs.
- If your organization is planning to broaden internationally, it’s important to be sure that your tech will likely be compliant with totally different rules in your goal nations.
- To simply and rapidly adapt to altering rules, it’s best to design your system to be modular and configurable.
With that framework in thoughts, you’ll be capable of see any problem in your means as a brand new alternative to make your fintech firm stand out.
Do you wish to discover out extra about how New10 helps small and medium-sized corporations get funding?
Try the web site for sources (Dutch solely).