Compliance - RASCI View¶
The Compliance function at Simpaisa is responsible for ensuring that all business activities meet applicable regulatory requirements, anti-money laundering (AML) obligations, and internal policy standards. Led by the Global Head of Regulatory Affairs (GH-RA) and supported by Compliance / Regulatory Analysts (Comp.An), the function owns the KYC / KYB and Customer Due Diligence process, and is the primary escalation point for sanctions screening hits, SAR / STR filings, and regulatory submissions. Compliance operates as both a first-line controller and a second-line oversight function across Simpaisa's multi-jurisdiction operating model.
Primary Processes¶
7.8 KYC / KYB and Customer Due Diligence¶
Compliance (Comp.An) is Accountable for the application received, document collection, identity verification, and approval / rejection steps. The Compliance Analyst is Responsible for risk scoring, EDD, and ongoing monitoring. CRO is Accountable for risk scoring and approval decisions. GH-RA is Consulted throughout.
Process Flow
| Process Step | COO | CFO | CRO | CISO | GH-RA | CH-PK | CH-BDNP | H-Legal | Comp.An | San.Scr | PM |
|---|---|---|---|---|---|---|---|---|---|---|---|
| 1. Application received | I | - | I | - | I | I | I | - | A | R | I |
| 2. Document collection | - | - | I | - | I | S | S | - | A | R | - |
| 3. Identity verification | - | - | I | C | I | - | - | - | A | R | - |
| 4. Sanctions screening | - | - | C | C | C | - | - | - | S | A | - |
| 5. Risk scoring | - | - | A | - | C | C | C | - | R | S | - |
| 6. EDD (if required) | C | - | A | - | C | C | C | S | R | R | - |
| 7. Approval / rejection | I | I | A | - | C | C | C | C | R | S | I |
| 8. Ongoing monitoring | I | - | A | C | C | S | S | - | R | R | - |
7.9 Sanctions Screening and Transaction Monitoring¶
The Compliance Analyst (Comp.An) is Responsible for hit determination, false positive review, escalation, SAR / STR filing, and record keeping. Global Head of Regulatory Affairs is Accountable for SAR / STR filing. Head of Legal is Accountable for record keeping and Responsible for SAR / STR filing.
Process Flow
| Process Step | COO | CRO | CISO | GH-RA | H-Legal | H-DevOps | Comp.An | San.Scr | DevOps.L | PM |
|---|---|---|---|---|---|---|---|---|---|---|
| 1. Screening trigger (transaction / entity) | I | I | I | - | - | I | I | R | A | I |
| 2. Automated screening (Eastnets) | - | I | C | - | - | S | S | R | A | - |
| 3. Hit / no-hit determination | - | I | - | - | - | - | S | A | S | - |
| 4. False positive review | - | C | - | C | - | - | R | A | - | - |
| 5. Escalation to Compliance | I | A | I | C | C | - | R | R | - | - |
| 6. SAR / STR filing (if required) | I | C | - | A | R | - | R | S | - | - |
| 7. Record keeping | I | C | C | C | A | S | R | R | S | - |
7.12 New Market Entry and Licence Application (Compliance steps)¶
Compliance is Accountable for licence application preparation, regulatory submission, and compliance setup for new markets. GH-RA holds the Accountable designation across these steps, with Comp.An providing Responsible execution.
Process Flow
| Process Step | CEO | COO | CPO | CFO | CRO | CISO | GH-RA | CH-PK | CH-BDNP | H-Legal | H-Treas | Comp.An | PCP | PMO | Int.Lead |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 1. Market assessment | A | C | R | C | C | - | R | C | C | - | C | S | S | S | - |
| 2. Entity incorporation | C | C | - | C | - | - | S | - | - | A | S | - | - | S | - |
| 3. Licence application preparation | C | C | I | C | C | - | A | S | S | R | S | R | - | S | - |
| 4. Regulatory submission | I | I | - | I | C | - | A | S | S | R | - | R | - | S | - |
| 5. Local team hiring | C | A | - | C | - | - | C | R | R | C | - | - | - | S | - |
| 6. Banking relationships | C | C | - | A | C | - | C | S | S | C | R | - | - | S | - |
| 7. Payment channel integration | - | C | C | - | - | C | I | S | S | - | - | - | R | S | A |
| 8. Compliance setup | - | C | - | - | C | C | A | R | R | S | - | R | - | S | - |
| 9. Go-live | A | R | R | C | C | C | C | R | R | C | C | C | S | S | S |
Supporting Role Summary¶
| Process | Designation | Notes |
|---|---|---|
| 7.2 Merchant Onboarding | R (KYB / CDD step) | Comp.An Responsible for KYB and CDD alongside Sanctions Screening |
| 7.3 Payment Transaction Processing - Collections | S | Comp.An supportive on transaction processing and reconciliation |
| 7.4 Payment Transaction Processing - Disbursements | R (compliance screening) | Comp.An Responsible for compliance screening of disbursement requests |
| 7.6 Crypto Off-Ramp Transaction Processing | R (AML / sanctions screening) | Comp.An Responsible for AML and sanctions screening on crypto receipts |
| 7.10 Settlement and Reconciliation | S | Comp.An supportive on exception investigation and reporting |
| 7.11 Incident Management and Escalation | C | Comp.An Consulted on classification, investigation, post-incident review |
| 7.14 Financial Reporting and Audit | R (regulatory filings) | Comp.An Responsible for regulatory filings |
| 7.16 Technology Change Management | C | Comp.An Consulted on impact assessment and CAB approval |
Role Key¶
| Code | Full Role |
|---|---|
| CEO | Chief Executive Officer |
| CPO | Chief Product Officer |
| COO | Chief Operating Officer |
| CFO | Chief Financial Officer |
| CISO | Chief Information Security Officer |
| CRO | Chief Revenue Officer |
| GH-RA | Global Head Regulatory Affairs |
| CH-PK | Country Head, Pakistan |
| CH-BDNP | Country Head, Bangladesh / Nepal |
| H-Legal | Head of Legal |
| H-Treas | Head of Treasury |
| H-DevOps | Head of DevOps |
| H-Sett | Head of Settlements |
| Comp.An | Compliance / Regulatory Analyst |
| San.Scr | Sanctions Screening |
| PM | Product Manager |
| PCP | Payment Channel Partnerships |
| PMO | PMO Manager |
| Int.Lead | Integration Lead |
| DevOps.L | DevOps Lead |
| R | Responsible - performs the work |
| A | Accountable - single owner, approves output |
| S | Supportive - provides active assistance |
| C | Consulted - must be consulted prior to decision |
| I | Informed - notified after the fact |