Since 2016 I have been heading COREDO and every day I see how one discipline changes the resilience and value of businesses in Europe, Asia and the CIS: a competent whistleblowing program in fintech. It has long ceased to be a “compliance box” and has become an element of corporate governance that affects Licensing, access to banking infrastructure, cost of capital and customer trust. The COREDO team has implemented dozens of deployments for payment organizations, neobanks, crypto platforms, brokers and companies building multi-jurisdictional structures in the EU, the UK, Singapore and Dubai. Below is my practice summary: what the EU directive requires, how to launch a system in 8–12 weeks, where the ROI is, and how to scale solutions across an international group.
Why fintech needs a whistleblowing program
Fintech companies operate under increased scrutiny from regulators and payment infrastructure. Payment licenses, PSD2 processes, EBA Guidelines on governance, AML/CTF frameworks and operational resilience requirements converge on one point: the ability to quickly detect and remediate breaches. An internal whistleblower program provides a controlled early-warning channel, not a stream of leaks to social media and journalists.
Regulatory framework: directives and laws
EU directive on the protection of whistleblowers 2019/1937 obliges organizations with 50+ employees, as well as companies from regulated sectors, to establish internal reporting channels and protect whistleblowers from reprisals. Employer obligations under the EU directive include:
- a secure and accessible internal channel (including anonymous reporting channels where permitted by national law);
- appointing persons responsible for processing reports and conducting internal investigations;
- response to a complaint: acknowledgement of receipt within 7 days and final feedback within 3 months;
- a non‑retaliation policy and legal mechanisms to protect whistleblowers.
National implementing laws in EU countries introduce details: in some places anonymity is explicitly encouraged, in others it is left to the company’s discretion. COREDO’s practice confirms: even where anonymity is not mandatory, the market (banks, partners, auditors) regards anonymous channels as best practice.
In the United Kingdom the FCA expects mature whistleblower protection procedures (including a “whistleblowing champion” for large firms; see SYSC 18). For payment and banking groups, the EBA Guidelines on internal governance and reporting expectations apply: a corporate whistleblowing policy is considered part of the internal control system. PSD2 strengthens requirements for operational incidents and security; an effective complaints system helps to detect and document them.
Architecture and technologies of a mature system
I describe a reference target architecture that the COREDO team develops for fintechs.
- Channels: protected feedback forms (web), secure drop, hotline with recording, mailbox, channel for third parties (external channel for complaints by a third party: external reporting). For anonymity we use end-to-end encryption of messages, the ability to upload files, metadata and the degree of pseudonymization.
- Case management: tools for case management allow registering, routing and investigating reports; important are automation of complaint triage, prioritization of incidents and SLAs for response. Role separation (RBAC), access control and privilege separation are mandatory.
- Information security: ISO 27001 and SOC 2 standards for whistleblowing providers; PCI DSS is relevant if investigations involve payers and elements of payment data — then we design a strict separation of environments. Audit log and data integrity control, logging and auditing of actions in the system, chain of custody of digital evidence: without these, investigations and e-discovery risk failing in court.
- Submission technologies: external whistleblowing provider (SaaS) versus on-premise. SaaS speeds up the launch and covers multi-jurisdictionality, but requires legally correct data transfers (DPA, SCCs, list of subprocessors). On-premise gives maximum control and may be justified for banks/exchanges. The solution developed by COREDO for one payments group combines a SaaS portal for the employee and an on-prem evidence repository.
- ML/NLP: we apply ML/NLP capabilities for classifying complaints and identifying systemic risks cautiously: automatic scoring for triage, thematic clustering, highlighting PEP/sanctions triggers, but with a constant human-in-the-loop. Machine learning for identifying fraud patterns works well together with AML alerts data.
Integration of AML and KYC
Integration of whistleblowing with AML and KYC turns reports into operational signals for monitoring. Customer and employee complaints often highlight weak spots: fake accounts, trade in «mules», incompetent EDD, breaches of sanctions policy. In COREDO’s practice, a support operator’s complaint helped identify a limit‑circumvention scheme in a neobank; linking the complaint to the TM system reduced time‑to‑block to hours.
KYC processes and the impact of complaints on monitoring are expressed in three streams:
- risk re-scoring of the client and segment;
- cases about employees and contractors (third‑party risk) → review of access and functions;
- escalation to the FIU when signs of money laundering are detected.
AML compliance and interaction with complaints require clear procedures for dividing responsibilities among the CCO, DMLRO and the investigations team, to avoid conflicts of interest.
Implementation in a fintech company: step-by-step
I distilled the key steps into a practical roadmap. The COREDO team typically completes the rollout in 8–12 weeks for a startup and 12–16 weeks for a mature PSP.
- Diagnostics and architecture
- compliance audit of the directive at the group level;
- map of jurisdictions and assessment of international delineation for complaints;
- data protection impact assessment (DPIA) for whistleblowing;
- choice of model: SaaS vs on‑premise, requirements for end‑to‑end encryption, secure drop.
- Policy and documentation
- template of internal policy on whistleblowing for fintech: objectives, scope, channels, roles and responsibilities (DPO, CCO, CRO, CTO), timelines 7 days / 3 months, non‑retaliation, data retention, interaction with EU regulators;
- corporate documentation: regulations, investigation procedures, incident response plan and business continuity;
- anti‑corruption policy and reports of violations – align with the overall compliance framework.
- Technological implementation
- provider selection and licensing, contracts with service providers, DPA and SCCs;
- integration with ERM/CRM/HR systems, RBAC configuration, audit log;
- testing of logging, integrity control, chain of custody, WORM storage.
- Processes and SLA
- legal assessment of complaints and triage: classification of legal significance, conflicts of interest, routing;
- SLA for responding to reports, KPI time‑to‑resolution, % of confirmed complaints;
- internal investigation protocol for reports of violations, forensic investigation, e‑discovery.
- Training and communications
- training of staff and awareness raising (awareness) with a focus on non‑retaliation;
- communication strategy for employees and stakeholders, multilingualism, FAQ;
- external channel for complaints from clients, partners and counterparties.
- Pilot and launch
- control period with parallel manual duplication, «hotline» for questions;
- preparation for external audits and regulator inspections, dry‑run with internal audit;
- reporting to the board of directors (board oversight), corporate governance and whistleblowing in one package.
Cross-border data and Schrems II
Scaling a program across multiple jurisdictions creates three types of challenges: legal, technical, and managerial. Managing multijurisdictional privacy requires local addenda to the policy, local case managers, and central coordination for cross-border matters. How to ensure cross-border transfer of complaint data? We use SCCs, encryption “in transit” and “at rest”, pseudonymization and data minimization, as well as technical measures for Schrems II (key management in the EEA, provider’s lack of access to the keys).
ROI and performance metrics
The assessment of ROI for implementing a whistleblowing system is based on the following metrics:
- cost‑per‑case, time‑to‑resolve, time‑to‑acknowledge;
- % of confirmed complaints and repeat incidents;
- prevented loss: avoided fines, losses from fraud, legal expenses;
- indirect benefits: lower insurance costs, improved terms with correspondent banks, increased attractiveness to investors.
The cost of implementation vs savings from prevented violations in a typical PSP is recouped in 9–18 months. In one of COREDO’s cases, complaints from the front office exposed a cashback theft scheme; the prevented loss in the first six months exceeded the budget for a three‑year subscription to the SaaS platform.
COREDO case studies: neobank and PSP
Case study: implementation in a neobank. The company operated in several EU countries and in the United Kingdom, serving millions of customers. The goal was a single reporting system for employees, as well as an external channel for customers and partners. Scaling the whistleblowing system across the international group required decoupling local legal particularities from centralized case management. COREDO implemented a SaaS solution with an on‑prem evidence archive, E2E encryption, RBAC, integrations with HRIS and TM, and an ML module for prioritization. The board of directors received quarterly KPI reports, and «tone from the top» lowered barriers to reporting. As a result, time‑to‑resolution fell by 47%, and the % of substantiated complaints stabilized at a healthy 32–38%.
Case study: a PSP licensed in the EU with operations in Dubai and Singapore. Regulators expected strict oversight of contractors and third‑party risk. COREDO developed a corporate policy, connected an external third‑party complaints channel, set up chain of custody, e‑discovery, and procedures for cooperation with external investigative authorities. In one incident an internal complaint led to an AML escalation and the correct filing of reports with the FIU. The regulator’s review concluded without sanctions.
C-level liability in the absence of a system
Legal risks when there is no complaints system include sanctions for non‑compliance with the EU directive, refusal or restriction of a license, increased regulatory scrutiny and tougher terms from payment partners. Legal liability of C‑level executives for the absence of a complaints system is not theoretical: in several countries leaders may face administrative liability. Employment law and protection against employee reprisals cover dismissal, demotion, harassment and indirect sanctions; a non‑retaliation policy and employee protections must be documented and applied in practice.
Criteria for choosing a provider
Recommendations for selecting a platform provider for complaints:
- compliance with ISO 27001 and SOC 2 Type II, independent audits, pentest results;
- end-to-end message encryption, secure drop, protected forms, no tracking;
- audit log, integrity control, immutable storage of critical artifacts;
- flexible RBAC model, segregated duties, delegation without revealing the informant’s identity;
- API integrations with ERM/CRM/HR, SSO, SCIM;
- transparent DPAs, list of subprocessors, options for data in the EEA, Schrems II compatibility;
- SLA for availability and time-to-acknowledge, clear total cost of ownership.
Technical choices: SaaS vs on-premise. For most fintech startups SaaS is more practical due to speed, cost, and continuous updates. Banks, exchanges and custodians often choose on-prem or hybrid.
Interaction with the regulator: roles
Roles and responsibilities: DPO: data protection, DPIA and cross-border transfers; CCO: methodology, triage and engagement with regulators; CRO – embeds the results into the risk map; CTO – security and integrations; internal audit: independent review of effectiveness and fraud investigation. Board oversight: a mandatory part of corporate governance.
Issues of engagement with EU regulators and national authorities are resolved through protocols: when and how to escalate, who makes contact, which notification templates are used. European Banking Authority reporting requirements and EBA Guidelines help set the structure. FCA expectations on whistleblower protection in the UK are useful to incorporate even for firms operating only in the EEA – it improves discipline.
Anonymous vs Identified
Anonymity and pseudonymization of reports increase willingness to report, especially in hierarchical cultures or in distributed teams. The advantages of anonymity – more signals, less fear. Drawbacks: difficulty asking clarifying questions and the risk of abuse. A practical compromise: an anonymous channel with the option for two-way communication, pseudonymization in case management, and a clear filter for ‘noisy’ signals. A non-retaliation policy also applies to identified reports; this is an important marker of maturity.
Company integration and licensing
Registering a legal entity in the EU: the impact on compliance becomes apparent immediately. When opening bank accounts, obtaining licenses (payment services, forex, crypto), as well as when expanding into the UK, Singapore or Dubai, regulators and banks expect to see not only AML/KYC‑policies but also a functioning complaints system. The AML and corporate support services provided by COREDO include linking whistleblowing with sanctions policies, anti‑corruption, compliance risk management, and corporate ethics.
Preventing Repeat Violations
Preventive measures and reduction of repeat violations depend on proper “closing the loop”: root cause analysis (root cause), action items, implementation controls and their verification by internal audit. Change management (change management) when implementing new controls and communications with employees reduce resistance and improve adoption.
- time‑to‑acknowledge and time‑to‑resolution;
- % of confirmed complaints and depth of root cause analysis;
- share of complaints that led to changes in policies/processes;
- employee awareness level, training coverage;
- ROI metrics: cost‑per‑case, prevented loss, time‑to‑resolve.
Forensics: evidence in court
Record-keeping and storage of evidence in accordance with the law: a foundational discipline. Internal audit and fraud investigations rely on the chain of custody, version control, hash sums, storage in secure containers, and segregation of access. Forensic investigations into internal breaches and e-discovery prepare the company for litigation; precise procedural logic increases the chances of a successful defense.
Timeline and stages of a startup and a mature group
Timeline and stages for implementing a complaints system for a fintech startup:
- Weeks 1–2: diagnosis, DPIA, architecture.
- Weeks 3–6: policy, contracts, SaaS configuration, integrations.
- Weeks 7–8: training, pilot, launch, short audit.
For a corporate group:
- Weeks 1–4: group framework, local addenda, DPIAs and TIAs.
- Weeks 5–10: integrations, migration from local “inboxes”, training and communications.
- Weeks 11–16: pilot in key countries, scaling, preparation for external audit.
How COREDO helps
At COREDO we cover the entire cycle: from choosing a provider and building processes to integration with AML/KYC and preparation for regulator inspections. The COREDO team has delivered projects in the EU, Czechia, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai; this helps account for local nuances and partner bank requirements. For neobanks and PSPs a package is available: policies and regulations, DPIA and Schrems II compliance, integrations with HR/ERM/TM, training, a KPI dashboard and an annual effectiveness audit.
Recommendations for C-level executives on one page
– Assign ownership at the board level and designate responsible persons (DPO, CCO, CRO, CTO).
– Ensure a multichannel approach: internal and external channels, anonymity, two-way communication.
– Adopt a non‑retaliation policy and real protections for EU whistleblowers.
– Integrate the system with AML/KYC, HR and ERM; set up automation for triage and SLAs.
– Conduct a DPIA, configure cross-border transfers per Schrems II, data minimization and pseudonymization.
– Set up an audit log, integrity controls, chain of custody; prepare e‑discovery.
– Choose a provider with ISO 27001/SOC 2, E2E encryption and a clear DPA.
– Introduce KPI and ROI metrics; run a pilot and regular external and internal audits.
– Build a communication strategy and regular training; remember third parties and contractors.
– Keep a response and business continuity plan ready; update measures after each case.
Conclusions
Whistleblowing is not a mere box‑ticking requirement under the directive, but a management tool that protects licenses, turnover and reputation. Companies that take AML, KYC, data protection and complaints systems equally seriously gain in decision‑making speed, control quality and market trust. In a multi‑jurisdictional growth environment — from the EU to Singapore and Dubai — a unified, technological and legally sound whistleblowing program becomes a condition for scaling.
I support transparent, effective systems that bring benefits to business and people. If you are preparing to register a legal entity in the EU, aiming for a new financial license or want to strengthen corporate governance, embed whistleblowing into the architecture from day one. COREDO’s practice shows: a properly designed and honestly implemented program pays off, reduces risks and makes the company stronger – regardless of jurisdiction and stage of development.