Fintech Compliance: My Experience with Regulations

Oak of life — foundation and resilience
Oak of life — foundation and resilience

Fintech Compliance: My Experience with Regulations

When I started working in fintech, the first thing I needed to figure out was: which requirements apply to us? It turned out there were quite a few regulations, and each required its own approach.

I’ll share the regulatory requirements I worked with and how I built a compliance system. This is personal experience, not an official guide.

Where I Started

The company already had some security foundations, but fragmented: something implemented here, something covered there. There was no systematic approach.

First, I compiled a list of all applicable requirements. That’s where things got interesting.

Bank of Russia Regulations

The Bank of Russia is the main regulator for financial organizations. The requirements are serious, but once you understand them — they’re logical.

Regulation No. 683-P

The key regulation on information protection in banking. The goal is to prevent unauthorized money transfers.

Main requirements:

The requirements are detailed, but in practice each measure finds its application.

Regulation No. 787-P

Requirements for information protection in the Central Bank’s payment system. Focus on protecting payment data and process continuity.

Regulation No. 821-P

Procedure for information protection in money transfers. Detailed protection at each stage of payment processing.

When implementing, I had to work closely with developers — many requirements are built into the architecture.

STO BR BFBO-1.8-2024

Standard on security for remote identification and authentication. Relevant for online banking and remote services.

Emphasis on protection against fraud in customer identification.

STO BR IBS

Comprehensive standard on information security of banking systems:

This is a whole system, not just a set of requirements. You need to build processes, configure monitoring, train people.

GOST R 57580.1-2017: Basic Protection Measures

The standard “Financial Operations Security. Information Protection of Financial Organizations” defines the basic set of organizational and technical measures.

Protection Levels

The standard defines several protection levels with different requirements. You need to determine the applicable level for your company.

This requires analyzing: data volume, system criticality, risks. It’s not quick, but you can’t move forward without this analysis.

Organizational and Technical Measures

The standard describes a system of interconnected requirements.

Organizational measures:

Technical measures:

Important: measures must work together. You can’t implement only technical or only organizational measures.

Choosing Protection Measures

You don’t need to implement everything at once. First assess risks, then choose adequate measures. This avoids excessive investment while maintaining the necessary protection level.

Implementation Completeness

Measures must be fully implemented. Formally creating a policy doesn’t mean you’re protected. Better to do less, but well.

Protection at All Lifecycle Stages

The standard requires protection at all stages: from design to decommissioning.

This means close work with development: implementing secure development practices, code analysis, security testing.

One of the hardest areas — developers are used to focusing on functionality. But gradually security becomes part of the culture.

PCI DSS: Working with Cards

International standard for those who process payment cards. Requirements are strict but logical:

The hardest part — limiting data storage. You can’t store full card numbers and CVV longer than necessary. I had to rework part of the system.

But when everything works — you feel calmer. Data is protected, monitoring is configured, the system is resilient.

152-FZ: Personal Data

The personal data law applies to everyone who processes it. Especially important in fintech — we work with customers’ financial data.

Main requirements:

The requirements are basic, but need to be implemented properly. It’s important to actually protect data, not just formally.

How I Built the Compliance System

After understanding the requirements, I started practical work. I didn’t try to cover everything at once — I made a plan.

Stage 1: Audit

Conducted an audit of the current state: what exists, what works, what’s only on paper. This took a month.

Turned out some requirements were met, but not systematically. Measures for one requirement weren’t used for another. Unification was needed.

Stage 2: Prioritization

Defined priorities:

Stage 3: Implementation

Started implementing gradually. First basic measures that cover multiple requirements. Then specific ones.

Important: don’t do it “for the checkbox.” Each measure must actually work.

Stage 4: Training

Most important — training employees. Without understanding “why,” the system doesn’t work.

Conducted training for different groups: developers, operators, management. Each with its own approach.

Result

After six months there was a compliance system that actually worked. Not perfect, but functional:

The main thing — the system isn’t formal. Each measure has practical application. The result is visible: incidents decreased, audits pass successfully.

Key Takeaways

Don’t fear regulations
Requirements seem complex, but they’re logical. Each solves a specific problem.

Systematic approach is critical
You can’t cover requirements individually. One measure can cover multiple requirements.

Practice over theory
You can write lots of documents, but if they don’t work — it’s useless. Better less, but quality.

Communication matters
Explain to people “why.” When they understand the goal — they perform better.

Compliance is a process
Not a one-time event. Need to constantly monitor, improve, adapt.

Conclusion

Regulations are constantly updated — need to track changes and adapt the system.

If you’re starting to work with fintech compliance: study the requirements, conduct an audit, define priorities. Move gradually.


In the next article I’ll share practical cases of implementing security standards.

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