Business plan, capital evidence, management, ownership and formal documentation.
Initial orientation
What are you planning?
Beyond documents
The application is only the visible tip.
Authorisation readiness emerges when the business model, responsibilities, processes and systems tell the same story.
Responsibilities, segregation of duties, controls and traceable decision-making.
From customer onboarding and AML controls to reporting lines, staffing and outsourcing.
Systems, information security, third parties, business continuity and robust evidence.
What is applied for must be capable of being operated, governed and audited once authorisation has been granted.
Regulatory Map
Four layers. One consistent target model.
Legislation defines the regulatory perimeter. Organisational and technology requirements determine how the firm meets it over time.
Authorisation basis
Which activity will be performed and to what extent?
Governance
How will management, controls, risk and compliance be organised?
Technology
How will systems, data and service providers remain controlled and resilient?
Ongoing supervision
Which notifications, reports, controls and audits apply during operations?
Process logic
Not a straight line.
A manageable process.
1
Project
Clarify business model and target market
2
Classification
Define activities and authorisation scope
3
Architecture
Plan organisation, roles and evidence
4
Implementation
Build documentation, processes and systems
5
Verfahren
Coordinate submission and follow-up questions
6
Operations
Transfer authorisation into BAU
↶ Iteration is part of the process. Good project governance makes questions, dependencies and decisions visible early.
Strategic options
Nicht jedes Project braucht denselben Weg.
Own authorisation
For firms that intend to own and develop the regulated business model independently.
- High strategic autonomy
- Own governance and resources
- Full ongoing responsibility
Partner model
Regulated services are delivered with a partner under a clearly defined allocation of roles.
- Precise service delineation
- Interface management
- Transparent dependencies
Tied-agent model
For certain investment services, acting as a tied agent may be an option.
- Not a universal exemption
- Acting on behalf and under liability
- Observe control and instruction structures
The viable structure depends on the specific activity, target model and commercial parameters. Online guidance does not replace an individual legal assessment.
Projektsteuerung
The bridge between requirements and reality.
Legal counsel defines the regulatory framework. Project management translates it into responsibilities, decisions, processes and reliable deliverables.
Project management is not an additional cost block.
It protects the investment in the process by reducing friction, inconsistent workstreams and late fundamental decisions.
Requirements registerConsolidate obligations, evidence and sources
connectedStakeholder managementSponsors, counsel, functions and providers
coordinatedConsistency controlApplication, policies, processes and systems
alignedDecision LogDecisions, assumptions and dependencies
traceableReadiness managementFrom application to operational launch
manageableBriefing Cards
Worth knowing
Network perspectives
Specialised perspectives.
One shared understanding.
The next useful step
Clarify the project before complexity becomes expensive.
Whether initial classification, an ongoing application or the transition to operations: the starting point is a shared understanding of the target model, roles and open decisions.
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