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Nothing Ventured Nothing Gained
By Alex Manson
By Alex Manson
Chapter 6
Compliance: The Agile Compliance Officer
Chapter Contributor(s)
Benedicte Nolens, former CCO SC Ventures
Change requires agile action and decision making.
Making the jump
In early 2019, I received a call from Simran Gill at SC Ventures: they had done their research and thought my profile might be a match for leading the SC Ventures Compliance workstream. At the time, I was at Circle, working for the CEO and having a ball in the emerging field of crypto assets. So, I had doubts about leaving for a new role.
As the first New York Department of Financial Services Bitlicense holder, there were many rules applicable to Circle. We had a strong and vibrant compliance team and took a more phased and risk-prioritised approach, just as any startup would. Financial institutions used to do this when they were smaller, including when I helped build up the compliance framework for the Asian footprint of Goldman Sachs 24 years earlier. For me, this was the greatest difference about life at Circle – it was free – free to think, free to be agile, free to innovate.

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.

The importance of delegation
For startup-style innovation to work in a bank’s governance, you need to start by defining who has the authority to set the compliance program. Unless this authority rests with the Chief Compliance Officer (CCO) of the venture arm, it will be a difficult and slow ride, as any other person will need to escalate many matters that they could otherwise have resolved. In our case, approval wait times post-escalation could take many months – too long in the context of new ventures.
To achieve proper delegation and understand our degrees of freedom (or lack of them), we needed to map out and understand the legal and regulatory obligations that applied to the corporate group and, therefore, its startup ventures. For example, the degrees of freedom of foreign subsidiaries of UK banks are confined by subsidiary undertakings under the Companies Act. So it took us many months to get the proper definition of these obligations, but once we did it, the direction of travel became a lot clearer.

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.

What can I do to help?

This mindset indicates a genuine willingness to help.

Your suggestion may be tricky to implement. How about we [consider the following]?

This response is positive in that it offers an alternative approach.

It's not within my responsibility.

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.

I'll get to it as soon as I can, but I have other priorities.

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.

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