W-22: Country Operations Ways of Work

Field	Value
Document	W-22
Title	Country Operations Ways of Work
Status	Draft
Owner	Country Heads
Created	2026-04-05
Review	Quarterly
Depends On	W-01 (Company Operating Rhythm), W-20 (Operations Ways of Work), STD-GOV-137 (Department Mandates and Decision Rights), Regulatory Playbooks (PK, BD, NP, IQ, AE, KSA)

Purpose

Define how Simpaisa's country teams operate within the matrix structure, interact with central functions, and deliver on their local obligations. Simpaisa operates across five active markets (PK, BD, NP, IQ, AE) with KSA in pre-launch. Each market has distinct regulatory requirements, banking infrastructure, and commercial dynamics, but all share a common technology platform and centralised support functions.

1. Country Team Structure

1.1 Current Country Leadership

Market	Country Head	Reports To	Local Team Size (Approx.)
Pakistan (PK)	Noor Ali	CEO	~80 (includes central functions based in PK)
Bangladesh (BD)	Sanjana Farid	CEO	~25
Nepal (NP)	Sanjana Farid (dual-hatted)	CEO	~10
Iraq (IQ)	TBD	CEO	~8
UAE (AE)	TBD	CEO	~15 (includes HQ functions)
KSA	TBD	CEO	Pre-launch

1.2 Country Head Mandate

Country Heads are accountable for:

• Revenue delivery against country targets set in the annual plan.
• Regulatory compliance in their market, supported by the Global Head Regulatory.
• Partner and merchant relationships in their market, supported by the COO.
• Local talent — hiring, retention, and performance management of local staff.
• Stakeholder management — regulators, banking partners, government agencies.

Country Heads are not accountable for:

• Platform engineering (CDO).
• Global product strategy (CDO / CPO).
• Group treasury and settlement (CFO).
• Global security and compliance frameworks (CDO / CISO / Global Head Regulatory).

1.3 Matrix Reporting

Country-based staff in central functions (e.g., a QA engineer based in Dhaka) report to their functional head (e.g., CTO), not the Country Head. The Country Head has a dotted-line coordination role for logistics, office management, and local regulatory matters.

2. Interaction with Central Functions

2.1 CDO Organisation

Interaction	Mechanism	Cadence
Platform feature requests	Product backlog via CPO	Weekly planning
Local integration requirements	Jira ticket tagged with market code	As needed; triaged within 48 hours
Incident escalation (technical)	#ops-engineering Slack channel	As needed; per W-20 escalation matrix
Security incidents	Immediate escalation to CISO	As needed
Data requests / analytics	Request via Data team	5 business day SLA
Local infrastructure needs	Request via DevOps team	Per capacity planning cycle

2.2 COO Organisation

Interaction	Mechanism	Cadence
Daily operations coordination	Daily ops stand-up (W-20 §1.2)	Daily
Partner management	Shared partner scorecard (W-21)	Monthly review
Settlement issues	Direct escalation to operations lead	As needed
SLA tracking	Shared SLA dashboard	Continuous
New partner onboarding	Joint onboarding process (W-21 §1)	As needed

2.3 CFO Organisation

Interaction	Mechanism	Cadence
Monthly financial reporting	Country P&L submission	By 3rd business day of following month
Settlement reconciliation	Daily reconciliation sign-off	Daily
Budget requests	Quarterly budget review	Quarterly
Treasury / pre-funding	Pre-funding request to Treasury	As needed; 48-hour notice for large amounts
Pricing changes	Pricing proposal to Commercial + CFO	As needed; per STD-GOV-137

2.4 Global Head Regulatory

Interaction	Mechanism	Cadence
Regulatory reporting	Per market regulatory playbook	Per playbook schedule
Regulatory change alerts	Email + Slack #regulatory channel	As identified
Licence renewals	Joint tracking (§4 below)	Per market schedule
Audit preparation	Joint preparation (Country Head + Regulatory)	As scheduled
STR filing	Country compliance officer → Global Head Regulatory	As needed; within 24 hours of detection

3. Per-Country Regulatory Reporting

Each market has specific regulatory obligations documented in the relevant Regulatory Playbook:

Market	Regulator(s)	Playbook	Key Reporting Obligations
PK	SBP, FMU, PTA	REGULATORY-PLAYBOOK-PK	Monthly transaction reports to SBP; STR filing to FMU; annual compliance audit
BD	Bangladesh Bank (BB), BFIU	REGULATORY-PLAYBOOK-BD	Monthly returns to BB; STR filing to BFIU; quarterly AML reports
NP	NRB, FIU-Nepal	REGULATORY-PLAYBOOK-NP	Monthly reports to NRB; STR filing to FIU-Nepal; annual licence renewal
IQ	CBI	REGULATORY-PLAYBOOK-IQ	Monthly transaction reports to CBI; quarterly compliance reviews
AE	CBUAE, SCA	REGULATORY-PLAYBOOK-AE	Quarterly returns to CBUAE; annual audit; ongoing sanctions screening
KSA	SAMA	REGULATORY-PLAYBOOK-KSA	Pre-launch: licence application and sandbox requirements

Country Head responsibility: Ensure all regulatory reports are submitted on time. The Global Head Regulatory provides templates, reviews submissions, and maintains the compliance calendar (W-31).

4. Local Incident Response

4.1 Decision Matrix: Local vs Central

Incident Type	Handled By	Escalation
Local partner downtime (single channel)	Country operations team	If >2 hours: escalate to COO (W-20 §3)
Regulatory inquiry or inspection	Country Head + Global Head Regulatory	Immediate notification to CEO
Local fraud pattern	Country operations + compliance officer	If systemic: escalate to CISO (CDO)
Platform-wide incident	Central engineering (CDO)	Country Head informed; not leading response
Local office / HR issue	Country Head	If legal: escalate to HR Head (Atiya Aly)
Local media / PR issue	Country Head	Immediate escalation to CEO
Settlement failure (single partner)	Country operations team	If >1 settlement cycle: escalate to COO + CFO

4.2 Regulatory Incident Response

When a regulator contacts the country team (inspection, inquiry, show-cause notice):

1. Country Head notifies the Global Head Regulatory (Shoukat Bizinjo) within 1 hour.
2. Global Head Regulatory notifies the CEO within 2 hours.
3. Country Head and Global Head Regulatory jointly prepare the response.
4. Legal counsel engaged if the matter involves potential penalties or licence risk.
5. All communications with the regulator are logged and filed in the regulatory management system.

5. Country P&L Ownership

5.1 What Country Heads Own

P&L Line	Country Head Accountability
Revenue	Merchant acquisition, volume growth, partner activation
Direct costs	Local staff costs, office costs, local partner fees
Settlement costs	Partner settlement fees (negotiated jointly with COO)
Regulatory costs	Licence fees, audit fees, compliance costs

5.2 What Country Heads Do Not Own

P&L Line	Owned By
Platform engineering costs	CDO
Global infrastructure costs	CDO
Group overheads (HQ, legal, audit)	CFO
Transfer pricing	CFO

5.3 Financial Accountability Cadence

• Monthly: Country P&L reviewed by Country Head, submitted to CFO by 3rd business day.
• Quarterly: Country Head presents P&L performance at the ELT Quarterly Strategy Review.
• Annually: Country Head submits budget proposal for the following year by Q3.

6. Monthly Country Report

6.1 Report Format

Each Country Head submits a monthly country report to the CEO and ELT by the 5th business day of the following month.

Required sections:

1. Executive summary — 3–5 bullet points covering the month's key developments.
2. Financial performance — Revenue vs. target, costs vs. budget, key variances explained.
3. Transaction volumes — By channel, by partner, month-over-month trend.
4. Partner health — Scorecard summary (per W-21), new partners onboarded, partners at risk.
5. Regulatory update — Reports filed, inspections conducted, regulatory changes pending.
6. Merchant activity — New merchants onboarded, merchants churned, pipeline summary.
7. Team update — Headcount, open positions, key hires/departures.
8. Risks and issues — Top 3 risks with mitigation status.
9. Next month priorities — Top 5 priorities for the coming month.

6.2 Review Process

• CEO reviews all country reports by the 7th business day.
• CFO reviews financial sections and flags discrepancies.
• COO reviews operational sections.
• Key items are escalated to the ELT Monthly Business Review (per W-01).

7. New Market Onboarding Pattern

When Simpaisa enters a new market, the following pattern is followed:

7.1 Phase 1: Market Assessment (3–6 months)

Activity	Owner	Output
Regulatory landscape analysis	Global Head Regulatory	Regulatory feasibility report
Market sizing and commercial case	Commercial	Business case document
Technical feasibility (local infrastructure, partners)	CDO	Technical feasibility report
Legal entity requirements	CFO + Legal	Entity setup plan
Board approval	CEO → Board	Go/no-go decision

7.2 Phase 2: Market Entry (6–12 months)

Activity	Owner	Output
Country Head appointed	CEO	Named Country Head
Legal entity established	CFO + Legal	Registered entity
Licence application(s) submitted	Global Head Regulatory + Country Head	Application filed
Local banking relationships established	COO + Country Head	Partner agreements
Platform extension (market configuration, local channels)	CDO Engineering	Market live in staging
Local team hired (operations, compliance, commercial)	Country Head + HR	Team in place
Regulatory sandbox / pilot (if required)	Country Head + Global Head Regulatory	Sandbox approval

7.3 Phase 3: Launch (1–3 months)

Activity	Owner	Output
Licence granted	Regulator	Active licence
Production go-live with initial partners	CDO Engineering + Operations	Live transactions
First merchants onboarded	Country Head + Commercial	Revenue generating
Post-launch monitoring (30 days)	Operations	Performance baseline
Country added to standard reporting cadences	COO	Country in operating rhythm

7.4 Phase 4: Steady State

• Country integrated into W-01 Company Operating Rhythm.
• Country Head participates in ELT Monthly Business Review.
• All standard Ways of Work documents apply.

Appendix: RACI

Activity	Country Head	CEO	COO	CDO	CFO	Global Head Regulatory
Country revenue delivery	R/A	I	I	I	I	-
Local regulatory compliance	R	I	I	I	I	A
Monthly country report	R	A	I	I	I	I
Local partner relationships	R	I	A	C	I	I
Local incident response	R	I	C	C	I	C
Country P&L management	R	I	I	I	A	-
New market onboarding	R	A	C	C	C	C