Two months later, my future boss sent me a message assuring me that, if what was holding me back was the worry that I wouldn’t have enough to do, this certainly wouldn’t be the case at SC Ventures. That convinced me to make the leap – and indeed, from the day of my arrival, I haven’t stood still. In only two years, we had laid the foundations for the ventures you are reading about in this book. Each of them has required different, right-sized compliance approval and focus, and the paragraphs below detail my learnings and recommendations.
Change – particularly as it relates to innovation and fintech – requires agile action and decision making. The Senior Manager & Certification Regime (SMCR), introduced after the 2007 Global Financial Crisis, makes both of these actions difficult. SMCR brought a level of demonstrable personal accountability to roles that was not there previously.
After these foundations were in place, SC Ventures needed an experienced CCO who would properly prioritise the focus between different ventures all at different stages. We broadly did this as follows:
We determined if the venture needed a regulatory licence to operate. If so, its governance would need to closely mimic the Bank’s. If not, we had more freedom to create the right-size policies and standards. We spent a lot of time on this effort.
If regulated, we recommended hiring a venture compliance team early, as they needed to help integrate compliance systems and regulatory technology. The venture would only succeed if this was done during the design and build of the tech stack. We found this was especially relevant for the following technologies: non-face-to-face onboarding, fraud control, sanctions name screening feeds, and transaction screening.
For unregulated ventures, we gave startups more leeway while maintaining key policies and standards, either due to legal and regulatory obligations on the group or for good hygiene purposes.
We balanced agile with the disciplined phasing of compliance work across the portfolio of ventures. No day is the same when working with one startup, and even less so when working with many of them at the same time. Every day was disrupted by a multitude of issues, and it took a lot of discipline to remain focused on what had to be in place before the beta launch of every venture in the portfolio.
We supported learning by design. Startups don’t have unlimited budgets and they can easily burn through cash. This meant that it was essential for the CCOs to roll up their sleeves and draft, plan and execute tasks by the timelines set.
This mindset indicates a genuine willingness to help.
This response is positive in that it offers an alternative approach.
This mindset creates a barrier between the project as a business and advisor; it lacks ownership and empathy.
My/our concern is …
If I had a dollar for each time I’ve heard this, I would be rich. Concerns aren’t helpful. Positive alternatives or suggestions are.
We all have other priorities. Unless the team understands the timelines, it won’t be able to deliver on theirs or seek alternative support if needed. Be upfront and very clear on your timelines.