# Fintech Launch Readiness Checklist

> Regulatory items below are orientation, not legal advice. Financial services regimes vary
> sharply by jurisdiction and by activity, and the details decide the outcome. Confirm your
> position with qualified counsel before launch.

**Product:** _______________  **Owner:** _______________  **Date:** _______
**Jurisdictions:** _______________

## 1. Permission to operate

- [ ] The regulated activity being performed is identified precisely
- [ ] Authorisation, licence, exemption or agent status confirmed **in writing**
- [ ] If operating under another firm's permission, the agreement is signed and its limits
      understood
- [ ] Client money / safeguarding requirements identified
- [ ] Consumer-facing communications reviewed against the applicable rules
- [ ] Complaints procedure exists and is published

🔴 "We are just the technology provider" is a position that requires legal confirmation, not an
assumption. It frequently does not survive contact with the regulated activity actually being
performed.

## 2. Money movement

- [ ] Every path money can take is drawn, including failure and reversal paths
- [ ] **Every payment operation is idempotent** — a retried request cannot pay twice
- [ ] Idempotency keys generated by the client, stored, and honoured
- [ ] Timeouts do not create ambiguity — you can always determine whether a payment happened
- [ ] Partial failure handled: money left neither in limbo nor duplicated
- [ ] Refund, reversal and chargeback paths built, not assumed

**Test performed: submit the same payment twice.** Result: _______________

The double-payment defect is the most common serious bug in payment systems, and it is nearly
always a missing or ignored idempotency key.

## 3. Ledger integrity

- [ ] **Double-entry ledger** — every movement has a matching pair
- [ ] Ledger is append-only; corrections are new entries, never edits
- [ ] Balances derived from the ledger, not stored and updated independently
- [ ] Currency handled in **minor units as integers**, never floating point
- [ ] Rounding rule defined, documented and consistent
- [ ] Multi-currency conversions record the rate and its timestamp

## 4. Reconciliation

- [ ] Automated reconciliation against every external party — bank, processor, scheme
- [ ] Runs daily, with a defined cut-off
- [ ] **A break process exists**: who investigates, in what time, and who is told
- [ ] Unreconciled items age-tracked and escalated
- [ ] Reconciliation status visible to someone accountable

**What happens to an unexplained break older than a week?** _______________

A reconciliation nobody acts on is a report. The break process is the control.

## 5. Financial crime

- [ ] KYC / identity verification appropriate to the risk
- [ ] Sanctions screening at onboarding **and on an ongoing basis**
- [ ] Transaction monitoring with tuned thresholds
- [ ] Suspicious activity reporting route defined, with a named responsible person
- [ ] Records retained for the required period
- [ ] Staff training completed

## 6. Data and security

- [ ] Card data handling scope determined; PCI DSS obligations understood
- [ ] Card data not stored unless genuinely required and permitted
- [ ] Personal and financial data encrypted in transit and at rest
- [ ] Access to production financial data restricted, logged and reviewed
- [ ] Production data not copied into test environments unmasked
- [ ] Penetration test completed and findings addressed

## 7. Operational resilience

- [ ] Behaviour when a payment provider is unavailable — queue, fail, or fail over
- [ ] Customer-facing message for each failure mode
- [ ] Recovery objectives defined and tested
- [ ] **Restore tested on ____ — took ____**
- [ ] Incident process names who decides, who communicates, and regulatory notification duties
- [ ] Dependencies on third parties documented, with their own resilience assessed

## 8. Before go-live

- [ ] End-to-end test with real money, small amounts, including a refund
- [ ] Reconciliation run on that test and balanced
- [ ] Duplicate submission tested
- [ ] Rollback plan that does not strand customer funds
- [ ] Support team briefed on what to do when money appears missing
- [ ] Someone is accountable for the financial position daily

## Sign-off

| | Name | Date |
|---|---|---|
| Engineering | | |
| Finance / ledger owner | | |
| Compliance | | |
| Legal confirmation obtained | | |
| Approved for launch | | |