The fintech compliance stack
Deals, cards, then the regulator.Fintech compliance arrives in layers, each triggered by a business event. Map the triggers and the stack builds itself in the right order — miss one and it announces itself mid-deal or mid-application.
Layer 1 — The commercial layer (SOC 2, and often ISO 27001)
Trigger: enterprise partners, banks, and platforms asking for proof. SOC 2 Type II is the US default; ISO 27001 joins when European or APAC counterparties enter the pipeline. Build them as one control set — fintechs almost always end up needing both.
Layer 2 — The card layer (PCI DSS)
Trigger: cardholder data touching your architecture. The scope-first playbook applies with special force in fintech: tokenize and outsource capture aggressively, because SAQ A versus SAQ D is an order-of-magnitude difference in permanent compliance load.
Layer 3 — The privacy layer (GDPR and kin)
Trigger: EU users or EU enterprise customers. DPAs, transfer mechanisms, and the operational rights machinery that procurement reviews — financial data raises the review’s intensity.
Layer 4 — The regulator (MAS TRM and equivalents)
Trigger: a license. This layer differs in kind, not degree — a regulator’s judgment replaces an auditor’s sampling, board accountability replaces policy sign-off, and the outsourcing register joins the core artifacts. Equivalent regimes exist across jurisdictions; MAS TRM is the archetype and the deepest content gap in this industry’s tooling.
The stack principle
One control set, many mappings, evidence collected once. Every layer reuses the last one’s foundation — which is why the fintechs that plan the stack spend a fraction of what the fintechs that discover it spend. Planning it is literally the engagement our founding team’s history was built for.
MAS TRM framework guide
What the MAS Technology Risk Management guidelines require of licensed financial institutions in Singapore — governance, resilience, and audit expectations.
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What's the right first framework for a fintech?
Almost always SOC 2 — it's what enterprise partners and banks request first in US-centric pipelines. PCI DSS joins the moment card data enters your architecture (scope it before you build), and regulatory frameworks arrive with licenses, not before.
Do fintechs need PCI DSS if a processor handles the cards?
You need to validate at whatever level your integration leaves you — fully outsourced flows can mean SAQ A, the lightest path. The architecture decision is the compliance decision; make it deliberately and early.
When does MAS TRM enter the picture?
Before the license application, not after approval. MAS assesses technology risk readiness as part of licensing, and governance evidence — board minutes, tested recovery, an outsourcing register — can't be retrofitted credibly.
MAS TRM vs ISO 27001 — How MAS TRM differs from ISO 27001 — regulator vs certifier, recovery expectations, outsourcing oversight, and incident clocks — for Singapore fintechs.
SOC 2 vs ISO 27001 — SOC 2 vs ISO 27001 compared on buyer expectations, cost, timeline, and structure — with the decision rule by market, and when to run both on one control set.