Oversight & controls
Governance & Control Expectations
Governance is not “paperwork”. It’s how a counterparty decides your scope is real, your controls are predictable, and your risk is containable.
Informational only. Expectations vary by business model, record
scope, and counterparty risk appetite.
Core
Decision structure
Clear roles, approvals, escalation paths, and ownership of risk decisions.
Core
Operating controls
Controls that match your scope: onboarding, monitoring, complaints, incidents, and reporting discipline.
Core
Proof & consistency
Website language, policies, logs, and actual operations must all tell the same story.
Key persons
Minimum coverage areas (role-based)
Use roles, not names, so this page stays future-proof and does not create misrepresentation risk.
Governance roles
Board / OversightApproves risk appetite,
major counterparties, and scope changes.
Executive leadAccountable for operations,
delivery, and incident escalation.
Risk / Compliance ownerOwns monitoring
approach, exceptions, and reporting cadence.
Operational roles
Operations ownerControls around funds flows,
reconciliation, refunds, and complaints handling.
Technology ownerAccess control, change
management, logging, and incident response process.
Finance / TreasuryFunds custody posture, cash
controls, and external audit readiness.
If you publish names, ensure the public record and your disclosures
match. Otherwise: keep it role-based.
Controls matrix
What counterparties typically expect to exist
Control areas (future-safe)
operational
Governance cadence
Board minutes (non-fake), risk appetite review, policy
approvals, and a scope-change process.
KYC / onboarding posture
Client type rules, prohibited geographies, screening approach,
and escalation path for high-risk cases.
Funds controls
Segregation (if applicable), reconciliation cadence,
refunds/withdrawals, and exception handling logs.
Technology controls
Access controls, privileged access review, change management,
monitoring, and incident response playbooks.
Monitoring & reporting
Ongoing monitoring triggers, suspicious activity escalation,
complaints KPI tracking, and record retention discipline.
Verification should always anchor to
registry.neveslicensingauthority.org for record
scope and conditions.
Governance is easiest when scope is clean.
Start with scope mapping, then build controls that match it.
Start with scope mapping, then build controls that match it.
Next in sequence:
Capital markets business models.
