Unlocking compliant growth
What if compliance was not simply about stopping risk, but helping businesses grow safely?
In this episode of Making payments make sense, Ecommpay Chief Compliance Officer Willem Wellinghoff joins Jason Thomas to explore how financial crime, AI, regulation and new technologies are reshaping modern compliance – and why the best compliance leaders need to understand the business, not stand apart from it.
Listen to podcast | Episode 3: Unlocking compliant growth
Read the episode transcript
Intro:
Hello, and welcome to Making payments make sense – Ecommpay’s podcast, where we unpack the ideas, challenges and changes shaping the future of payments.
For this episode, we’re bringing you a focused conversation with Willem Wellinghoff, Chief Compliance Officer at Ecommpay, on the realities of compliance leadership in a fast-moving fintech market.
This interview was originally recorded for another series and is being repackaged here for Ecommpay’s channels because the themes it explores remain highly relevant: financial crime, regulatory scrutiny, licensing, talent, AI, crypto, and what it really takes to build a modern compliance function.
In the conversation, Willem speaks with Jason Thomas about the changing shape of financial crime risk, the FCA’s growing expectations, what makes a strong MLRO, and why curiosity, judgement and commercial awareness matter just as much as technical knowledge.
We hope you enjoy the episode – and if you do, please subscribe to Making payments make sense so you don’t miss what’s next.
Let’s get into it.
Jason Thomas:
I’m Jason Thomas, co-founder of Alexander Barnes, and today we are lucky enough to have CCO of Ecommpay, Willem Wellinghoff, welcome, Willem.
Willem:
Thanks for having me.
Jason Thomas:
And how are you? Are you okay?
Willem:
Fantastic, thank you.
Jason Thomas:
How was your commute?
Willem:
All right, it’s not too bad. It’s about two hours door to door to the office in the morning, but yeah, it’s all good.
Jason Thomas:
Man, well, thanks for coming on. Just wanted to start by asking you, first of all, how’s things with Ecommpay at the moment?
Willem:
Very much so. We’re in this really what I would call the growth phase. We’ve been around for 13 years and we’ve had a very lucky ride in terms of being able to withstand all the storms.
But we’re in this really nice growth phase. We’ve got a lot of good focus, a great team behind it, and very ambitious plans over the coming years.
Jason Thomas:
Amazing. Where do you guys operate at the moment? Which sort of locations?
Willem:
So we’ve got our HQ on Old Street in London. But at the same time, we’ve got offices in Cyprus, in Limassol and Nicosia, two beautiful hubs – old town and beach central, so to speak.
But we’ve also got an amazing office in Riga, Latvia, not too far from old town. Yeah, it’s a lovely place to be.
Jason Thomas:
Awesome.
Financial crime trends
Jason Thomas:
A couple of things we’re seeing at the moment – lots of different trends within financial crime and compliance, when it comes to restructures, cuts. Are you seeing that yourself, and what’s your view on it?
Willem:
Yeah, I think the whole space is actually quite dynamic at the moment.
I think there’s been a lot of focus, especially on what’s happened in the world of sanctions. There’s been a lot of focus on it. There is no leeway – you’re wrong or you’re right in that sense.
But I would say just generally on financial crime, I think there’s a lot more focus on countries from a national risk assessment perspective, and just the way things are now so borderless in crime.
You’ve got to be on it so quickly. It’s so sophisticated now in terms of the crime that teams have to be very experienced. They’ve got to know exactly what they’re looking at. And if you don’t have the right people within your team, it can be a real risk.
Jason Thomas:
Yeah, okay, that makes sense. Are there any particular skill sets you see working better than others from your experience?
Willem:
What I would say is, from a person perspective – and I suppose this is right for every role – I think you’ve got to have a real mindset of being curious.
I think curiosity plays a very important role. So it’s not just, “what does the regulation say?” or “what does this say?” It’s about how do people actually do this, right? And understanding the mechanisms of how the crimes are committed, and what the paths of that are, so that you can actually step in the footsteps of a criminal, so to speak, to be able to try and pre-empt it or stop it.
I’ll give you a great example. It’s actually quite easy to spoof liveness tests if you know how to do it. A very easy way of spoofing a liveness test is putting a small filter over the camera, and the cameras don’t pick it up.
The only way you would actually know whether there is a filter over the webcam is by doing a small flash, and if the flash turns out that it’s a blank screen, you know that there’s a filter.
So you’ve got to know the techniques that criminals are applying. It is becoming so sophisticated now, especially with the use of technology and AI in particular. You’ve got to really be ahead of it.
So in terms of people and talent, what I would look for is: are they not just applying the regulatory mindset, but are they understanding development, understanding the systems that are out there, and do they have an innovative mindset and approach?
Technology, AI and compliance roles
Jason Thomas:
Makes sense. And coming on to technology, you’re seeing that having an impact, and cuts, and people getting let go because technology can now take over some parts of the role?
Willem:
I think cuts – a lot of people use that as a scare word. I think it’s evolving.
Technology is definitely helping to make things more efficient. But will it replace us? No, I don’t think it will. Especially with AI, there is still room for error and bias. So you’ve got to have a human element that is still having some control over it.
But it makes your role a lot more efficient, 100 per cent.
Jason Thomas:
Do you look for people that have got more of an understanding of AI when you’re interviewing candidates?
Willem:
Yeah, totally. Like I said before, for me, if you’ve got a curious mindset, so having a mindset towards innovation and adaptive technologies, I think that is important because we all have to ultimately work with it.
But if I come back to customer expectations – whether it’s retail, whether it’s merchants, we work with merchants – they want access to financial services as soon as possible, right?
The demands of clientele and customers are that they want everything at their fingertips, as soon as possible. So the only way you can really scale at pace is to utilise innovation, technology and the human element in one cohort very well together.
FCA focus and customer lifecycle risk
Jason Thomas:
Thank you for that. Moving on to – well, sticking with financial crime – the FCA seems to have a high agenda on financial crime at the moment. Are you seeing that, and what are you seeing?
Willem:
Yeah, I would say it’s been on the agenda with them for a while, and it won’t come off the agenda for some time. It’s always on their risk outlook.
But what we’re seeing is a lot more intelligence coming out of the regulator. You see a lot more thematic reviews coming out. Obviously they’re working closely with firms on the supervision side, but what we’re seeing now is much more detail on what good and bad look like, and what their expectations are, which is something we never really got a couple of years ago.
Whereas now it’s a lot more detailed – something you can actually use to adapt your own practices.
Jason Thomas:
And are there any specific areas that they really dial into?
Willem:
Well, transaction monitoring systems, sanctions screening – that’s been a big one the last couple of years – but transaction screening is a big one as well.
So how are you testing your systems? What methodologies are you applying?
Customer due diligence will always be a core focus in financial crime, but I think a lot of people sometimes forget what happens once customers are onboarded. That actually is probably one of the most important things for practitioners in financial crime.
What happens after they have onboarded? How do you look at the journey? What are the patterns? What are the transaction types? That’s where there’s a lot more focus.
Jason Thomas:
Any advice for people that maybe get that customer journey bit, and then can’t kind of finish it or evolve it in the right way?
Willem:
Yeah, I would say a customer doesn’t stop at onboarding.
For me, it’s very important – the customer lifecycle from start to finish. And whether that’s a good customer from start to finish, or they then end up moving on to another party, you’ve always got to question why.
Why did they leave? Why did something go wrong? Work back from that and build some root understanding of what’s going on.
EMI applications and regulatory burden
Jason Thomas:
That’s good advice.
Hot topic for us at the moment, personally from a recruitment point of view, is companies contacting us in regards to EMI applications. Why do you think the pass rate is low, and why do companies struggle to actually get this approved?
Willem:
I would say, if you look at going back ten years ago, being a payment services institution and EMI was really becoming quite a hot topic to get licensed.
What we saw in the UK generally is that there was a lot more willingness to authorise firms. What subsequently happened – and we saw this in particular around Covid – is that some companies were going under.
And as a consequence, the FCA were being pointed at and asked, “why didn’t you stop this?” I would say then that the supervision and intelligence teams at the regulator were not as well staffed as what they are now.
As a consequence, I think people realised those failures have a big impact on consumers. Ultimately they are a consumer protection regulator. Yes, they’ve got market integrity as well, but ultimately it’s about consumer protection.
So working back from when there was a real push to get people licensed and licences were being granted, I think the pendulum swung quite heavily the other way.
We’ve seen this in the digital assets space as well. Trying to get a registration, even though it’s under an AML registration currently in the UK, is almost impossible to get through. And then with the EMI space, I think people at the regulator just went, “we’ve got to be a bit more robust on how these market participants can play with integrity, having the right capital, the right team, the right substance, and where they are actually operating from.”
So the pendulum has swung very much the other way. I think the balance is coming back, but if you’re looking at it from a fintech founder position, you would probably say, “I don’t want to be in the UK at this moment in time. The regulatory burden is too high to come with the investment that I’ve got to manage and the runway that I have.”
One of the good things we are seeing is that there is a real commitment to bringing some of the timescales down. It used to be 12 months from a full application, but in reality it’s 12 plus. That’s now been brought back to 10 months, so we’ll see what more happens.
And I think the balance will be redressed to some extent. But the UK is not the only area where it’s difficult. We see this in the EU as a whole now. There are some jurisdictions that have just not issued any licence in the last 12 months.
So I think people realise how hard it is going into it.
Can AI help with authorisation processes?
Jason Thomas:
Do you think ChatGPT and AI can help people with the process? Obviously there’s a lot of reading, a lot of things that go into it. Do you think that can help minimise the upfront learning?
Willem:
Yeah, I play around a lot with AI. I look at the different models that are available in the market. Actually, we have our own AI environments.
And our Head of AI says, “Willem, you’re one of the most prolific and innovative users of our AI platform.” That’s because I’m so curious about it. I do this at 11 or 12 o’clock at night when I have a little bit of free space.
But I do think there is a space that AI can help with these things. But it’s only as good as the data you’re putting in.
So if you’re thinking, “hey, ChatGPT or Gemini or whatever, build an application pack that meets the regulatory factsheet”, it’s individual to each business.
That’s the key point. If you really want to build the right prompt, you’ve got to start with: what is the role that you want the AI to play? That’s key. And then you need to feed it enough data about your business and your business model and the plans that you’ve got to then start building a framework around it.
Then it’s: what do you want it to do?
So yes, you can use it if you’ve got the right question. But also, when you’re interviewed by the FCA, they’re looking at the people they’re meeting and whether they are dialled into that actual business, as opposed to a generic approach.
Jason Thomas:
Exactly right.
Willem:
Absolutely. I think this is what a lot of people start to forget now. The regulators want to know who they’re dealing with – whether you’re sincere, whether you’ve got the experience, whether you’ve got the best intentions for the business, its customers, but equally for the industry as a whole.
At the end of the day, they’re here to stay, and you’ve got to build the economy with the right integrity. If you’re not a fair player in the market, they won’t regulate you.
When to hire an MLRO
Jason Thomas:
What about the MLRO hire? So if you’re a start-up, when would you say they need to start looking at that hire? When should they bring them in or consider them?
Willem:
So it’s a great question. I think this is the conundrum. Damned if you do, damned if you don’t, because we all know that experienced AML resource comes at a cost.
But I think you have to start looking at these things very, very early on. There are ways you can go about it. There are ways you can build fractional support – part-time support initially.
But you’ve got to ensure that by the time you are close to getting authorised, you’ve got someone on board.
What I would say is try never to go with someone who’s never done this before. We see that a lot. I think it’s an education piece. I don’t think clients or prospects fully understand. I think they want to get someone in who is junior because of the cost element – they’re a new business, so there’s that cost and risk.
But they don’t fully understand that actually getting someone junior who hasn’t got the exposure is going to have a long-term effect.
Jason Thomas:
Yeah, totally. I think that’s the interesting conundrum we have in the industry, because there are only so many people that you can really choose from.
Willem:
Exactly. There’s only so much talent in the market. We’re no longer in the same environment where we could have a borderless pool from the EU, right? Since Brexit, the talent pool has become a lot smaller.
Sometimes it’s like finding a needle in a haystack for the right person, for the right role, in the business that you want.
But if you do want to have someone who’s fairly junior, who’s inquisitive and wants to learn, they also need to have the right support behind them. So yes, you could have someone junior, but they’re going to have to show that they are going to get the right qualifications – for example ACAMS or ICA type certifications – but also that they have external support they can tap into to help them as well.
Interim support and regulator relationships
Jason Thomas:
What about interim hires? Do you ever see that working when going for a licence? There are a lot of companies that contact us and want to get an interim in as opposed to hiring a permanent person.
Willem:
Yeah, I do see it working. I think if you’re open and transparent with the regulator – that we don’t have someone immediately on board right now, but we have an interim arrangement – it can work.
It may be one of the authorisation conditions. What we’re seeing as well is that regulators are saying, “we’ll give you this licence and authorisation, but subject to you meeting these conditions,” which will get you through those threshold conditions, so to speak.
Jason Thomas:
And what do you think firms that are doing well – maybe with good relationships with the FCA – are doing differently to the ones that aren’t performing well?
Willem:
I think if you really want to build up a really good relationship with the regulators, it’s all about openness, transparency and getting to know who you’re dealing with.
That actually is quite difficult, right? We’re large enough where we know who our supervisor is, and we have a regular dialogue with that person at least on a quarterly basis.
Is that a lot? I would say that’s probably the right thing for a company like us so that they know what’s going on within the business.
The difficult part when you’re building up and scaling from scratch is you don’t necessarily know who you’re dealing with at the regulator. But I think establishing a good relationship very early on, and also being very open and honest when things may not have gone so well, is important.
When there is a clear indicator of a breach that has had a massive impact, you’ve got to be open, right? And show that you are willing to take accountability.
But also, don’t just go to them when the problem has happened to you. We’re all human. We’re all working in an environment where nothing’s ever perfect. Something is going to go wrong at some point in time.
I don’t think anyone would expect otherwise. But I think when you know something has gone wrong, you don’t just go to the regulator and say, “by the way, this has gone wrong.” No – you’ve got to come with a plan.
Assess the critical aspect of what has gone wrong, question why it has gone wrong, and come to the regulator quite promptly, but also show what you have done to ensure that you’ve addressed the risks.
Because coming with the problem and no solution will make things much worse.
Jason Thomas:
Yeah, because that will spook them out.
Willem:
Exactly. They’ll think, well, you don’t know what you’re doing.
Top tips for EMI applicants
Jason Thomas:
Anyone listening to this who is maybe starting that journey – top three tips you’d give a company going for an EMI authorisation sort of application in maybe 2026?
Willem:
Yeah, totally. I think there are some really good resources that the regulators make available – what do you want to have in your business plan? What information needs to be in these business plans?
Do your diligence. Speak to people in the industry. Build that network. There are plenty of people, like myself, who are always willing to help people on those journeys. I think it’s really important you build the relationships.
And lastly, question: why are you doing this? What are you trying to do? And how are you going to do it?
If you can answer those questions well, that will help you make a successful application. Because that shows your purpose, and I think that plays into every critical business. If you don’t understand your why, your purpose, and what you are doing it for, then you’re missing something.
And then from there: what am I actually doing based on that purpose, and how am I going to do it, and what’s going to differentiate me from that person to that person?
Once you know how to build that, and with the connections and the network, and you pull on the resources that the regulators have, those are the key things that I think would help you make a successful application.
The MLRO role and misconceptions
Jason Thomas:
What about the MLRO? Obviously there’s a lot of misconception about that role. What do you think about it?
Willem:
Right, I think we’re in a world now where compliance, or even the MLRO function, is often seen as a role of business prevention – the BPOs of this world.
But I think you’ve got to look at this role slightly differently. It’s about revenue protection. That’s how I look at it.
But the MLRO role also has to be business-enabling in mindset.
But can you get away with no crime happening at all? No. I think if you have that mindset, you might as well not be in business.
So you’ve got to understand what the business tolerance to these things is. And the MLRO plays a critical function in that, because with that mindset you can advise: these are the things we need to be aware of, these are the things we’ve got to put in place, and if we don’t, this is how the risk is going to look when we set the risk appetite.
The other thing that you particularly see in early-stage start-ups and growth businesses is that sanctions is also part of the MLRO role. Sanctions is a really interesting one because in reality you should probably split that out, because it’s a very different framework.
With sanctions, you cannot have a risk. You either comply or you don’t.
Whereas with AML risks, you can still have some tolerance, but it’s about what controls you get in place.
Building credibility internally
Jason Thomas:
Do you think it’s more important than ever to build credibility internally with the team and the stakeholders, as an MLRO, to get buy-in?
Willem:
Totally. Again, it’s about relationships.
You’ve got to understand every component of the business. I think that’s a very important mindset. If you think you can just be in your own bubble and say, “you do as I say”, you’re not going to make that work.
I think it’s really important you understand how the product works. If you don’t know how the product works, how are you going to advise on the controls?
So understanding the product, understanding how operations want to interact with this – and I think this is the critical part. Operations are the executioner, right? And you are putting controls in place to allow them to execute against those controls.
So again, it’s about how do you deliver that? Good training, working together, building the right processes. But also ensuring that the people at the front end have the autonomy and capability to make the right decisions as well.
Tenure, movement and stepping up
Jason Thomas:
What would you say – and we deal with clients a lot on this – one of the things clients often pick up on is tenure. They’ll say, this person’s only been there two years, or three years. There is a big movement, as you know. Why do you think the MLRO role maybe moves more frequently than other specialisms?
Willem:
It’s a great question, actually. I’ve been thinking about that a lot over the last couple of weeks.
I think partially it’s culturally driven. I was in Cyprus last week for the 10th anniversary of ACAMS, which was a great conference, and obviously a lot of financial crime professionals and risk professionals were there.
I was just curious – how long have you been there? Eight years. Ten years. A long time. I was thinking, wow, 20 years? That’s crazy.
So how do you adapt? How do you not get institutionalised? What’s the way things are in that community? There is not a lot of movement from role to role because it’s such a small community – everyone knows everyone.
Whereas in the UK, the average tenure you see is two and a half, three years. So there is a lot of movement. I think that’s partially culturally driven.
I think it’s also driven by the sheer number of companies that there are available. The addressable market in Cyprus, Latvia, Lithuania – another big fintech hub – is smaller. Whereas in the UK, new start-ups happen all the time.
So if you’ve got the pockets, and you’ve got a really good purpose and people are energised by it, you’re able to attract them much quicker.
And more and more what you’re seeing is people wanting to move. People are looking at the UAE, for example, and moving there. Why? Because it’s still dynamic, a heavily investable market, and the whole environment on the legal, regulatory and financial crime side is evolving at pace.
If you’re progressive in mind, you would want to be part of that.
Jason Thomas:
I think there are just so many companies now. So much investment. Companies are offering equity, stocks.
From your point of view when you’re hiring, then how do you kind of grade candidates if you get a CV, for example, and it says two years, two years, two years?
Willem:
I don’t necessarily see job hopping as a bad thing. But one of the things I would ask is what has made you make those jumps?
I’d want to understand their motivations for change, not just because they see a new shiny thing.
If people say, “I didn’t really fit in. I just saw another opportunity to go somewhere else,” I would want to understand why they’re saying that. Why did you not fit in? What caused you to have that feeling?
Then you can sometimes see whether they were supported or not.
For me, my team are gold. I’m so lucky to have such a great team – not only engaging, but very curious, and they’ve built a very high degree of trust.
Challenges of the MLRO role
Jason Thomas:
What would you say the biggest challenges the MLRO deals with day to day then?
Willem:
I think it’s balance.
Trying to keep everything in balance is probably the hardest thing. And I say balance not only based on the sheer amount of workload they’ve got to get through in terms of working with operations and putting in controls, but also the dynamic landscape.
The landscape is always changing, especially when you’re working on a cross-border aspect as well. You’ve got to take into account different jurisdictions. One jurisdiction may not be as advanced as another, and some may be very advanced.
So that balance is one of the difficult things.
And the second challenge is: can you build up a level of trust? I think trust in this role, both internally and externally, is absolutely critical.
I ask my team sometimes: can I trust you with my life? If I can say yes to that – and they’re extraordinarily good performers as well – then you’ve got your key start.
Jason Thomas:
Sounds like you’ve got a great team.
Willem:
Oh, I’m very lucky, yes.
Advice for stepping into an MLRO role
Jason Thomas:
What about people looking to step into that role? There are so many candidates out there that want to make that step up. What would be the best piece of advice you’d give someone maybe at a deputy level looking for that first MLRO job?
Willem:
Never be afraid.
You should never be afraid of wanting to take that leap. A lot of the time people question themselves, or say, “I may not be able to do this because I don’t necessarily have the confidence.”
Don’t be afraid.
The greatest companies have come out of wanting to build something new, novel, and taking a risk. We see that in every great business.
If you’re not willing to put yourself out there, build up a little bit of confidence and be willing to take a chance – but also knowing that that won’t come easily, you’ve got to put some grit into it and make some sacrifices if you want to take that step up – that’s critical.
Moving from banking into fintech
Jason Thomas:
We’re seeing a lot of candidates in the banking space that are really trying to move into fintech, into payments, into crypto. When you’re hiring, some people don’t like it. They think maybe banking people are stuck in the past and it’s not as fast as fintech. What do you advise to those candidates, and do you entertain candidates from that space?
Willem:
Well, I do. I certainly do. I would never say no to anyone, quite frankly.
It is, though, quite a challenge when you’re dealing with people who have been in the banking sphere for such a long time, because they’ve been so used to the banking world. Big beasts – they don’t move fast. There are some very bureaucratic processes involved in big banks.
I think for someone wanting to come out of the banking world and into a very fast-paced fintech, the first thing you’ve got to try and get out of your mind is: “this is how we used to do it.”
You see that quite often. And I think this is for everyone coming into a new role – try and avoid bringing the bias that you had from your previous place into it.
Keep an open mind and don’t go off saying, “oh, in this place this is how we did it”, because it rubs people up the wrong way. You’re there because you want to build the trust and the brand and the company profile in the company you’re at now – not because you’ve always done it that way.
That said, there can absolutely be benefits. Especially if things worked well, and there were really good processes and governance structures. You can bring that across. So I wouldn’t discount those people at all.
Crypto and regulation
Jason Thomas:
What about crypto then? Do you think it’s fully landed yet, or still kind of shaping?
Willem:
I think it’s shaping.
It’s a very interesting one. When I have these discussions with people, most go, “oh, this is a fad, this is a scam, look at how many Bitcoin frauds there are.”
Do I think the industry is shaping up a bit? Yes, I do.
And I don’t think of this purely as crypto. I think the same thing happened when e-money became a thing. It started off with pre-loaded clips and people saying, “I’m going to load a card.” If you look at the history of finance, the same thing happened with credit. Credit wasn’t regulated, then it became regulated, and it took years for it to really get into the mainstream of regulation.
I think the nature of crypto is that a lot of people question what the purpose is. That’s where people have become a little bit confused – regulators, practitioners – you go, what would you use it for?
But I think there are a clear number of reasons why crypto is starting to build and will continue to evolve.
Jason Thomas:
Stablecoin is the hot topic for us.
Willem:
Yeah, and I’m quite excited about it. I remember three years ago I challenged the FCA at a conference – take stablecoin and crypto as a payment method, right? Not an investment.
If you were to use this as a payment instrument that could be settled immediately, that’s a use case. You could have cross-border transactions happen just like that, as opposed to waiting three or four days for funds to come through correspondent banking.
And I see that now actually starting to happen. We see documents coming from the Bank of England talking about stablecoin settlement capabilities, by issuing your own stablecoin token.
Great. We’re actually having these conversations now.
But that means borders will become even smaller, and that means instant settlement. That comes with its own risks – liquidity risk, fraud risk – and how do you pull upon that when something does go wrong?
That whole risk environment is going to be very interesting to come.
What crypto founders may get wrong
Jason Thomas:
What about crypto founders? Do you think there’s anything they’re getting wrong when it comes to regulation?
Willem:
Yeah, we have seen this. I think the traditional fintech founders maybe should go tech first, then fintech, because a lot of them come from a computing background.
They think, “we can do this better than anyone.” Utilise distributed ledger technology, it’s got more secure capabilities and protocols, and it can create a fast way of making payments or doing whatever the use case is.
That’s the mindset they have. And yes, you’ve got to have an appreciation of what you’re getting yourself into in the markets that you’re going into. That can be quite challenging.
What would Willem change?
Jason Thomas:
A couple of closing questions. If you could change one regulation, what would it be?
Willem:
There are so many.
We’re in the UK, particularly, such a heavily regulated market. If I’m looking at it just from a UK perspective, I wouldn’t necessarily change it too much, but I would have things done a lot quicker.
All the crypto and stablecoin work – we were so late to the market on that. And is it still the right way of thinking about it? No, it isn’t. It still needs a lot more evolution in my view.
So I wouldn’t say there is one particular regulation I would change. I would just change the speed. I think that’s true generally of regulators at this moment in time, especially in heavily regulated markets.
The speed to regulation based on the evolution that’s happening needs to be much quicker. If we’re not careful, the UK will lose out to other partners. You see the UAE, you see Singapore – they’re working at pace.
Staying current
Jason Thomas:
How do you stay current in a market you’ve been in for such a long time?
Willem:
I just love this market anyway.
I keep up to speed by looking at what’s going on in the news – fintech news, regulatory news. There are some great fintech resources out there, digital magazines, and like I said earlier, I build my own queries using AI to look at what regulators are moving on in particular spaces, and what’s happening in fintech more generally.
I’m also part of a great community of fintech founders, and you get some great insights on how people are thinking and what’s shaping their minds.
I think the fintech community is small yet large, if that makes sense. There is a lot of collaboration opportunity within it. There are some great networks, great conferences, and a lot of curious people.
Motivation and personal questions
Jason Thomas:
Obviously you’re in a very, very senior role. I guess it’s quite stressful. There must be easier roles out there. How do you stay excited in these type of roles? What keeps you motivated?
Willem:
It’s a great question. I think a lot of people in the industry who know me would say I’m a stickler for pain and a martyr – I like to go through the pain.
The reality is, I deeply care about it. Looking at Ecommpay, our purpose is to build inclusive payments processing platforms for merchants and their customers. That’s a purpose that is very well aligned to me.
I like to challenge the status quo. I’m never satisfied by just one thing – I always want to see what happens next. That gets me out of bed in the morning.
And then if I’m looking at it at a personal level, I’ve come from a family where my dad always challenged everything. He was never happy with one thing, he could always do things better. He was very entrepreneurial.
And I think that’s stayed with me. I always want to make sure my family has a better life. And for me, I do that for them.
Jason Thomas:
Brilliant. Love that answer.
If you weren’t in compliance, what would you be doing?
Willem:
I would love to be in music, and develop tools for musicians. Music is a great passion of mine. I play drums and guitar. I think without it I’d never really be able to escape.
Jason Thomas:
And you’re a big basketball fan, I’ve heard.
Willem:
I used to play it. When I lived in Belgium, I played in the Belgian league.
A long time ago now, obviously put on a few pounds.
But yeah, it’s something I still follow very closely. Big NBA fan.
Jason Thomas:
Who do you support?
Willem:
East and West Coast – East Coast, Boston Celtics. West Coast, LA Clippers.
Jason Thomas:
A couple of quick-fire questions, a little bit of fun. Would you say your morning routine is planned or chaotic?
Willem:
I’d say organised chaos is probably the right way.
It is structured to some degree. I know what time I need to wake up and all these things, but when you’ve got kids who need to go to school at the same time, and tubes, and all these kinds of things – thank God for having the capability of doing things on the mobile and the iPad nowadays. It makes it so much easier.
Jason Thomas:
Guilty pleasure – food, TV shows, podcast, anything?
Willem:
Food-wise, I love anything Malaysian. And chocolate – especially chocolate.
As for film, any kind of good horror movie. I love good horror movies. Anything that’s got a little bit of tension.
Jason Thomas:
Anyone in particular?
Willem:
One of my favourite movies is The Shining. Stanley Kubrick, I really like. A Clockwork Orange is one of my favourite books actually, from Anthony Burgess – one of my favourite books – but yes, Stanley Kubrick movies.
Jason Thomas:
And last question – if you could swap lives with anyone for a week?
Willem:
If it was music, and if he was still alive, it’d probably be John Bonham. He was the drummer of Led Zeppelin, my favourite band.
He was just the most incredible drummer out there. A jazz drummer that just played very hard. So if he was still alive and I had the opportunity to be someone that played back then, then it would be him.
Jason Thomas:
Well then, pleasure having you on.
Willem:
Thanks.
Jason Thomas:
Enjoyed talking to you.
Willem:
Thank you.
Outro:
That’s it for this episode of Making payments make sense.
This was a conversation worth sharing because it speaks directly to the pressures, trade-offs and decisions shaping compliance in fintech right now – from licensing and regulator engagement, to talent, AI, crypto and the evolving financial crime landscape.
If you enjoyed the episode, please subscribe to Making payments make sense for more sharp, practical conversations from across the world of payments.
Thanks for listening – and we’ll see you next time.
Hello, and welcome to Making payments make sense – Ecommpay’s podcast, where we unpack the ideas, challenges and changes shaping the future of payments.
For this episode, we’re bringing you a focused conversation with Willem Wellinghoff, Chief Compliance Officer at Ecommpay, on the realities of compliance leadership in a fast-moving fintech market.
This interview was originally recorded for another series and is being repackaged here for Ecommpay’s channels because the themes it explores remain highly relevant: financial crime, regulatory scrutiny, licensing, talent, AI, crypto, and what it really takes to build a modern compliance function.
In the conversation, Willem speaks with Jason Thomas about the changing shape of financial crime risk, the FCA’s growing expectations, what makes a strong MLRO, and why curiosity, judgement and commercial awareness matter just as much as technical knowledge.
We hope you enjoy the episode – and if you do, please subscribe to Making payments make sense so you don’t miss what’s next.
Let’s get into it.
Jason Thomas:
I’m Jason Thomas, co-founder of Alexander Barnes, and today we are lucky enough to have CCO of Ecommpay, Willem Wellinghoff, welcome, Willem.
Willem:
Thanks for having me.
Jason Thomas:
And how are you? Are you okay?
Willem:
Fantastic, thank you.
Jason Thomas:
How was your commute?
Willem:
All right, it’s not too bad. It’s about two hours door to door to the office in the morning, but yeah, it’s all good.
Jason Thomas:
Man, well, thanks for coming on. Just wanted to start by asking you, first of all, how’s things with Ecommpay at the moment?
Willem:
Very much so. We’re in this really what I would call the growth phase. We’ve been around for 13 years and we’ve had a very lucky ride in terms of being able to withstand all the storms.
But we’re in this really nice growth phase. We’ve got a lot of good focus, a great team behind it, and very ambitious plans over the coming years.
Jason Thomas:
Amazing. Where do you guys operate at the moment? Which sort of locations?
Willem:
So we’ve got our HQ on Old Street in London. But at the same time, we’ve got offices in Cyprus, in Limassol and Nicosia, two beautiful hubs – old town and beach central, so to speak.
But we’ve also got an amazing office in Riga, Latvia, not too far from old town. Yeah, it’s a lovely place to be.
Jason Thomas:
Awesome.
Financial crime trends
Jason Thomas:
A couple of things we’re seeing at the moment – lots of different trends within financial crime and compliance, when it comes to restructures, cuts. Are you seeing that yourself, and what’s your view on it?
Willem:
Yeah, I think the whole space is actually quite dynamic at the moment.
I think there’s been a lot of focus, especially on what’s happened in the world of sanctions. There’s been a lot of focus on it. There is no leeway – you’re wrong or you’re right in that sense.
But I would say just generally on financial crime, I think there’s a lot more focus on countries from a national risk assessment perspective, and just the way things are now so borderless in crime.
You’ve got to be on it so quickly. It’s so sophisticated now in terms of the crime that teams have to be very experienced. They’ve got to know exactly what they’re looking at. And if you don’t have the right people within your team, it can be a real risk.
Jason Thomas:
Yeah, okay, that makes sense. Are there any particular skill sets you see working better than others from your experience?
Willem:
What I would say is, from a person perspective – and I suppose this is right for every role – I think you’ve got to have a real mindset of being curious.
I think curiosity plays a very important role. So it’s not just, “what does the regulation say?” or “what does this say?” It’s about how do people actually do this, right? And understanding the mechanisms of how the crimes are committed, and what the paths of that are, so that you can actually step in the footsteps of a criminal, so to speak, to be able to try and pre-empt it or stop it.
I’ll give you a great example. It’s actually quite easy to spoof liveness tests if you know how to do it. A very easy way of spoofing a liveness test is putting a small filter over the camera, and the cameras don’t pick it up.
The only way you would actually know whether there is a filter over the webcam is by doing a small flash, and if the flash turns out that it’s a blank screen, you know that there’s a filter.
So you’ve got to know the techniques that criminals are applying. It is becoming so sophisticated now, especially with the use of technology and AI in particular. You’ve got to really be ahead of it.
So in terms of people and talent, what I would look for is: are they not just applying the regulatory mindset, but are they understanding development, understanding the systems that are out there, and do they have an innovative mindset and approach?
Technology, AI and compliance roles
Jason Thomas:
Makes sense. And coming on to technology, you’re seeing that having an impact, and cuts, and people getting let go because technology can now take over some parts of the role?
Willem:
I think cuts – a lot of people use that as a scare word. I think it’s evolving.
Technology is definitely helping to make things more efficient. But will it replace us? No, I don’t think it will. Especially with AI, there is still room for error and bias. So you’ve got to have a human element that is still having some control over it.
But it makes your role a lot more efficient, 100 per cent.
Jason Thomas:
Do you look for people that have got more of an understanding of AI when you’re interviewing candidates?
Willem:
Yeah, totally. Like I said before, for me, if you’ve got a curious mindset, so having a mindset towards innovation and adaptive technologies, I think that is important because we all have to ultimately work with it.
But if I come back to customer expectations – whether it’s retail, whether it’s merchants, we work with merchants – they want access to financial services as soon as possible, right?
The demands of clientele and customers are that they want everything at their fingertips, as soon as possible. So the only way you can really scale at pace is to utilise innovation, technology and the human element in one cohort very well together.
FCA focus and customer lifecycle risk
Jason Thomas:
Thank you for that. Moving on to – well, sticking with financial crime – the FCA seems to have a high agenda on financial crime at the moment. Are you seeing that, and what are you seeing?
Willem:
Yeah, I would say it’s been on the agenda with them for a while, and it won’t come off the agenda for some time. It’s always on their risk outlook.
But what we’re seeing is a lot more intelligence coming out of the regulator. You see a lot more thematic reviews coming out. Obviously they’re working closely with firms on the supervision side, but what we’re seeing now is much more detail on what good and bad look like, and what their expectations are, which is something we never really got a couple of years ago.
Whereas now it’s a lot more detailed – something you can actually use to adapt your own practices.
Jason Thomas:
And are there any specific areas that they really dial into?
Willem:
Well, transaction monitoring systems, sanctions screening – that’s been a big one the last couple of years – but transaction screening is a big one as well.
So how are you testing your systems? What methodologies are you applying?
Customer due diligence will always be a core focus in financial crime, but I think a lot of people sometimes forget what happens once customers are onboarded. That actually is probably one of the most important things for practitioners in financial crime.
What happens after they have onboarded? How do you look at the journey? What are the patterns? What are the transaction types? That’s where there’s a lot more focus.
Jason Thomas:
Any advice for people that maybe get that customer journey bit, and then can’t kind of finish it or evolve it in the right way?
Willem:
Yeah, I would say a customer doesn’t stop at onboarding.
For me, it’s very important – the customer lifecycle from start to finish. And whether that’s a good customer from start to finish, or they then end up moving on to another party, you’ve always got to question why.
Why did they leave? Why did something go wrong? Work back from that and build some root understanding of what’s going on.
EMI applications and regulatory burden
Jason Thomas:
That’s good advice.
Hot topic for us at the moment, personally from a recruitment point of view, is companies contacting us in regards to EMI applications. Why do you think the pass rate is low, and why do companies struggle to actually get this approved?
Willem:
I would say, if you look at going back ten years ago, being a payment services institution and EMI was really becoming quite a hot topic to get licensed.
What we saw in the UK generally is that there was a lot more willingness to authorise firms. What subsequently happened – and we saw this in particular around Covid – is that some companies were going under.
And as a consequence, the FCA were being pointed at and asked, “why didn’t you stop this?” I would say then that the supervision and intelligence teams at the regulator were not as well staffed as what they are now.
As a consequence, I think people realised those failures have a big impact on consumers. Ultimately they are a consumer protection regulator. Yes, they’ve got market integrity as well, but ultimately it’s about consumer protection.
So working back from when there was a real push to get people licensed and licences were being granted, I think the pendulum swung quite heavily the other way.
We’ve seen this in the digital assets space as well. Trying to get a registration, even though it’s under an AML registration currently in the UK, is almost impossible to get through. And then with the EMI space, I think people at the regulator just went, “we’ve got to be a bit more robust on how these market participants can play with integrity, having the right capital, the right team, the right substance, and where they are actually operating from.”
So the pendulum has swung very much the other way. I think the balance is coming back, but if you’re looking at it from a fintech founder position, you would probably say, “I don’t want to be in the UK at this moment in time. The regulatory burden is too high to come with the investment that I’ve got to manage and the runway that I have.”
One of the good things we are seeing is that there is a real commitment to bringing some of the timescales down. It used to be 12 months from a full application, but in reality it’s 12 plus. That’s now been brought back to 10 months, so we’ll see what more happens.
And I think the balance will be redressed to some extent. But the UK is not the only area where it’s difficult. We see this in the EU as a whole now. There are some jurisdictions that have just not issued any licence in the last 12 months.
So I think people realise how hard it is going into it.
Can AI help with authorisation processes?
Jason Thomas:
Do you think ChatGPT and AI can help people with the process? Obviously there’s a lot of reading, a lot of things that go into it. Do you think that can help minimise the upfront learning?
Willem:
Yeah, I play around a lot with AI. I look at the different models that are available in the market. Actually, we have our own AI environments.
And our Head of AI says, “Willem, you’re one of the most prolific and innovative users of our AI platform.” That’s because I’m so curious about it. I do this at 11 or 12 o’clock at night when I have a little bit of free space.
But I do think there is a space that AI can help with these things. But it’s only as good as the data you’re putting in.
So if you’re thinking, “hey, ChatGPT or Gemini or whatever, build an application pack that meets the regulatory factsheet”, it’s individual to each business.
That’s the key point. If you really want to build the right prompt, you’ve got to start with: what is the role that you want the AI to play? That’s key. And then you need to feed it enough data about your business and your business model and the plans that you’ve got to then start building a framework around it.
Then it’s: what do you want it to do?
So yes, you can use it if you’ve got the right question. But also, when you’re interviewed by the FCA, they’re looking at the people they’re meeting and whether they are dialled into that actual business, as opposed to a generic approach.
Jason Thomas:
Exactly right.
Willem:
Absolutely. I think this is what a lot of people start to forget now. The regulators want to know who they’re dealing with – whether you’re sincere, whether you’ve got the experience, whether you’ve got the best intentions for the business, its customers, but equally for the industry as a whole.
At the end of the day, they’re here to stay, and you’ve got to build the economy with the right integrity. If you’re not a fair player in the market, they won’t regulate you.
When to hire an MLRO
Jason Thomas:
What about the MLRO hire? So if you’re a start-up, when would you say they need to start looking at that hire? When should they bring them in or consider them?
Willem:
So it’s a great question. I think this is the conundrum. Damned if you do, damned if you don’t, because we all know that experienced AML resource comes at a cost.
But I think you have to start looking at these things very, very early on. There are ways you can go about it. There are ways you can build fractional support – part-time support initially.
But you’ve got to ensure that by the time you are close to getting authorised, you’ve got someone on board.
What I would say is try never to go with someone who’s never done this before. We see that a lot. I think it’s an education piece. I don’t think clients or prospects fully understand. I think they want to get someone in who is junior because of the cost element – they’re a new business, so there’s that cost and risk.
But they don’t fully understand that actually getting someone junior who hasn’t got the exposure is going to have a long-term effect.
Jason Thomas:
Yeah, totally. I think that’s the interesting conundrum we have in the industry, because there are only so many people that you can really choose from.
Willem:
Exactly. There’s only so much talent in the market. We’re no longer in the same environment where we could have a borderless pool from the EU, right? Since Brexit, the talent pool has become a lot smaller.
Sometimes it’s like finding a needle in a haystack for the right person, for the right role, in the business that you want.
But if you do want to have someone who’s fairly junior, who’s inquisitive and wants to learn, they also need to have the right support behind them. So yes, you could have someone junior, but they’re going to have to show that they are going to get the right qualifications – for example ACAMS or ICA type certifications – but also that they have external support they can tap into to help them as well.
Interim support and regulator relationships
Jason Thomas:
What about interim hires? Do you ever see that working when going for a licence? There are a lot of companies that contact us and want to get an interim in as opposed to hiring a permanent person.
Willem:
Yeah, I do see it working. I think if you’re open and transparent with the regulator – that we don’t have someone immediately on board right now, but we have an interim arrangement – it can work.
It may be one of the authorisation conditions. What we’re seeing as well is that regulators are saying, “we’ll give you this licence and authorisation, but subject to you meeting these conditions,” which will get you through those threshold conditions, so to speak.
Jason Thomas:
And what do you think firms that are doing well – maybe with good relationships with the FCA – are doing differently to the ones that aren’t performing well?
Willem:
I think if you really want to build up a really good relationship with the regulators, it’s all about openness, transparency and getting to know who you’re dealing with.
That actually is quite difficult, right? We’re large enough where we know who our supervisor is, and we have a regular dialogue with that person at least on a quarterly basis.
Is that a lot? I would say that’s probably the right thing for a company like us so that they know what’s going on within the business.
The difficult part when you’re building up and scaling from scratch is you don’t necessarily know who you’re dealing with at the regulator. But I think establishing a good relationship very early on, and also being very open and honest when things may not have gone so well, is important.
When there is a clear indicator of a breach that has had a massive impact, you’ve got to be open, right? And show that you are willing to take accountability.
But also, don’t just go to them when the problem has happened to you. We’re all human. We’re all working in an environment where nothing’s ever perfect. Something is going to go wrong at some point in time.
I don’t think anyone would expect otherwise. But I think when you know something has gone wrong, you don’t just go to the regulator and say, “by the way, this has gone wrong.” No – you’ve got to come with a plan.
Assess the critical aspect of what has gone wrong, question why it has gone wrong, and come to the regulator quite promptly, but also show what you have done to ensure that you’ve addressed the risks.
Because coming with the problem and no solution will make things much worse.
Jason Thomas:
Yeah, because that will spook them out.
Willem:
Exactly. They’ll think, well, you don’t know what you’re doing.
Top tips for EMI applicants
Jason Thomas:
Anyone listening to this who is maybe starting that journey – top three tips you’d give a company going for an EMI authorisation sort of application in maybe 2026?
Willem:
Yeah, totally. I think there are some really good resources that the regulators make available – what do you want to have in your business plan? What information needs to be in these business plans?
Do your diligence. Speak to people in the industry. Build that network. There are plenty of people, like myself, who are always willing to help people on those journeys. I think it’s really important you build the relationships.
And lastly, question: why are you doing this? What are you trying to do? And how are you going to do it?
If you can answer those questions well, that will help you make a successful application. Because that shows your purpose, and I think that plays into every critical business. If you don’t understand your why, your purpose, and what you are doing it for, then you’re missing something.
And then from there: what am I actually doing based on that purpose, and how am I going to do it, and what’s going to differentiate me from that person to that person?
Once you know how to build that, and with the connections and the network, and you pull on the resources that the regulators have, those are the key things that I think would help you make a successful application.
The MLRO role and misconceptions
Jason Thomas:
What about the MLRO? Obviously there’s a lot of misconception about that role. What do you think about it?
Willem:
Right, I think we’re in a world now where compliance, or even the MLRO function, is often seen as a role of business prevention – the BPOs of this world.
But I think you’ve got to look at this role slightly differently. It’s about revenue protection. That’s how I look at it.
But the MLRO role also has to be business-enabling in mindset.
But can you get away with no crime happening at all? No. I think if you have that mindset, you might as well not be in business.
So you’ve got to understand what the business tolerance to these things is. And the MLRO plays a critical function in that, because with that mindset you can advise: these are the things we need to be aware of, these are the things we’ve got to put in place, and if we don’t, this is how the risk is going to look when we set the risk appetite.
The other thing that you particularly see in early-stage start-ups and growth businesses is that sanctions is also part of the MLRO role. Sanctions is a really interesting one because in reality you should probably split that out, because it’s a very different framework.
With sanctions, you cannot have a risk. You either comply or you don’t.
Whereas with AML risks, you can still have some tolerance, but it’s about what controls you get in place.
Building credibility internally
Jason Thomas:
Do you think it’s more important than ever to build credibility internally with the team and the stakeholders, as an MLRO, to get buy-in?
Willem:
Totally. Again, it’s about relationships.
You’ve got to understand every component of the business. I think that’s a very important mindset. If you think you can just be in your own bubble and say, “you do as I say”, you’re not going to make that work.
I think it’s really important you understand how the product works. If you don’t know how the product works, how are you going to advise on the controls?
So understanding the product, understanding how operations want to interact with this – and I think this is the critical part. Operations are the executioner, right? And you are putting controls in place to allow them to execute against those controls.
So again, it’s about how do you deliver that? Good training, working together, building the right processes. But also ensuring that the people at the front end have the autonomy and capability to make the right decisions as well.
Tenure, movement and stepping up
Jason Thomas:
What would you say – and we deal with clients a lot on this – one of the things clients often pick up on is tenure. They’ll say, this person’s only been there two years, or three years. There is a big movement, as you know. Why do you think the MLRO role maybe moves more frequently than other specialisms?
Willem:
It’s a great question, actually. I’ve been thinking about that a lot over the last couple of weeks.
I think partially it’s culturally driven. I was in Cyprus last week for the 10th anniversary of ACAMS, which was a great conference, and obviously a lot of financial crime professionals and risk professionals were there.
I was just curious – how long have you been there? Eight years. Ten years. A long time. I was thinking, wow, 20 years? That’s crazy.
So how do you adapt? How do you not get institutionalised? What’s the way things are in that community? There is not a lot of movement from role to role because it’s such a small community – everyone knows everyone.
Whereas in the UK, the average tenure you see is two and a half, three years. So there is a lot of movement. I think that’s partially culturally driven.
I think it’s also driven by the sheer number of companies that there are available. The addressable market in Cyprus, Latvia, Lithuania – another big fintech hub – is smaller. Whereas in the UK, new start-ups happen all the time.
So if you’ve got the pockets, and you’ve got a really good purpose and people are energised by it, you’re able to attract them much quicker.
And more and more what you’re seeing is people wanting to move. People are looking at the UAE, for example, and moving there. Why? Because it’s still dynamic, a heavily investable market, and the whole environment on the legal, regulatory and financial crime side is evolving at pace.
If you’re progressive in mind, you would want to be part of that.
Jason Thomas:
I think there are just so many companies now. So much investment. Companies are offering equity, stocks.
From your point of view when you’re hiring, then how do you kind of grade candidates if you get a CV, for example, and it says two years, two years, two years?
Willem:
I don’t necessarily see job hopping as a bad thing. But one of the things I would ask is what has made you make those jumps?
I’d want to understand their motivations for change, not just because they see a new shiny thing.
If people say, “I didn’t really fit in. I just saw another opportunity to go somewhere else,” I would want to understand why they’re saying that. Why did you not fit in? What caused you to have that feeling?
Then you can sometimes see whether they were supported or not.
For me, my team are gold. I’m so lucky to have such a great team – not only engaging, but very curious, and they’ve built a very high degree of trust.
Challenges of the MLRO role
Jason Thomas:
What would you say the biggest challenges the MLRO deals with day to day then?
Willem:
I think it’s balance.
Trying to keep everything in balance is probably the hardest thing. And I say balance not only based on the sheer amount of workload they’ve got to get through in terms of working with operations and putting in controls, but also the dynamic landscape.
The landscape is always changing, especially when you’re working on a cross-border aspect as well. You’ve got to take into account different jurisdictions. One jurisdiction may not be as advanced as another, and some may be very advanced.
So that balance is one of the difficult things.
And the second challenge is: can you build up a level of trust? I think trust in this role, both internally and externally, is absolutely critical.
I ask my team sometimes: can I trust you with my life? If I can say yes to that – and they’re extraordinarily good performers as well – then you’ve got your key start.
Jason Thomas:
Sounds like you’ve got a great team.
Willem:
Oh, I’m very lucky, yes.
Advice for stepping into an MLRO role
Jason Thomas:
What about people looking to step into that role? There are so many candidates out there that want to make that step up. What would be the best piece of advice you’d give someone maybe at a deputy level looking for that first MLRO job?
Willem:
Never be afraid.
You should never be afraid of wanting to take that leap. A lot of the time people question themselves, or say, “I may not be able to do this because I don’t necessarily have the confidence.”
Don’t be afraid.
The greatest companies have come out of wanting to build something new, novel, and taking a risk. We see that in every great business.
If you’re not willing to put yourself out there, build up a little bit of confidence and be willing to take a chance – but also knowing that that won’t come easily, you’ve got to put some grit into it and make some sacrifices if you want to take that step up – that’s critical.
Moving from banking into fintech
Jason Thomas:
We’re seeing a lot of candidates in the banking space that are really trying to move into fintech, into payments, into crypto. When you’re hiring, some people don’t like it. They think maybe banking people are stuck in the past and it’s not as fast as fintech. What do you advise to those candidates, and do you entertain candidates from that space?
Willem:
Well, I do. I certainly do. I would never say no to anyone, quite frankly.
It is, though, quite a challenge when you’re dealing with people who have been in the banking sphere for such a long time, because they’ve been so used to the banking world. Big beasts – they don’t move fast. There are some very bureaucratic processes involved in big banks.
I think for someone wanting to come out of the banking world and into a very fast-paced fintech, the first thing you’ve got to try and get out of your mind is: “this is how we used to do it.”
You see that quite often. And I think this is for everyone coming into a new role – try and avoid bringing the bias that you had from your previous place into it.
Keep an open mind and don’t go off saying, “oh, in this place this is how we did it”, because it rubs people up the wrong way. You’re there because you want to build the trust and the brand and the company profile in the company you’re at now – not because you’ve always done it that way.
That said, there can absolutely be benefits. Especially if things worked well, and there were really good processes and governance structures. You can bring that across. So I wouldn’t discount those people at all.
Crypto and regulation
Jason Thomas:
What about crypto then? Do you think it’s fully landed yet, or still kind of shaping?
Willem:
I think it’s shaping.
It’s a very interesting one. When I have these discussions with people, most go, “oh, this is a fad, this is a scam, look at how many Bitcoin frauds there are.”
Do I think the industry is shaping up a bit? Yes, I do.
And I don’t think of this purely as crypto. I think the same thing happened when e-money became a thing. It started off with pre-loaded clips and people saying, “I’m going to load a card.” If you look at the history of finance, the same thing happened with credit. Credit wasn’t regulated, then it became regulated, and it took years for it to really get into the mainstream of regulation.
I think the nature of crypto is that a lot of people question what the purpose is. That’s where people have become a little bit confused – regulators, practitioners – you go, what would you use it for?
But I think there are a clear number of reasons why crypto is starting to build and will continue to evolve.
Jason Thomas:
Stablecoin is the hot topic for us.
Willem:
Yeah, and I’m quite excited about it. I remember three years ago I challenged the FCA at a conference – take stablecoin and crypto as a payment method, right? Not an investment.
If you were to use this as a payment instrument that could be settled immediately, that’s a use case. You could have cross-border transactions happen just like that, as opposed to waiting three or four days for funds to come through correspondent banking.
And I see that now actually starting to happen. We see documents coming from the Bank of England talking about stablecoin settlement capabilities, by issuing your own stablecoin token.
Great. We’re actually having these conversations now.
But that means borders will become even smaller, and that means instant settlement. That comes with its own risks – liquidity risk, fraud risk – and how do you pull upon that when something does go wrong?
That whole risk environment is going to be very interesting to come.
What crypto founders may get wrong
Jason Thomas:
What about crypto founders? Do you think there’s anything they’re getting wrong when it comes to regulation?
Willem:
Yeah, we have seen this. I think the traditional fintech founders maybe should go tech first, then fintech, because a lot of them come from a computing background.
They think, “we can do this better than anyone.” Utilise distributed ledger technology, it’s got more secure capabilities and protocols, and it can create a fast way of making payments or doing whatever the use case is.
That’s the mindset they have. And yes, you’ve got to have an appreciation of what you’re getting yourself into in the markets that you’re going into. That can be quite challenging.
What would Willem change?
Jason Thomas:
A couple of closing questions. If you could change one regulation, what would it be?
Willem:
There are so many.
We’re in the UK, particularly, such a heavily regulated market. If I’m looking at it just from a UK perspective, I wouldn’t necessarily change it too much, but I would have things done a lot quicker.
All the crypto and stablecoin work – we were so late to the market on that. And is it still the right way of thinking about it? No, it isn’t. It still needs a lot more evolution in my view.
So I wouldn’t say there is one particular regulation I would change. I would just change the speed. I think that’s true generally of regulators at this moment in time, especially in heavily regulated markets.
The speed to regulation based on the evolution that’s happening needs to be much quicker. If we’re not careful, the UK will lose out to other partners. You see the UAE, you see Singapore – they’re working at pace.
Staying current
Jason Thomas:
How do you stay current in a market you’ve been in for such a long time?
Willem:
I just love this market anyway.
I keep up to speed by looking at what’s going on in the news – fintech news, regulatory news. There are some great fintech resources out there, digital magazines, and like I said earlier, I build my own queries using AI to look at what regulators are moving on in particular spaces, and what’s happening in fintech more generally.
I’m also part of a great community of fintech founders, and you get some great insights on how people are thinking and what’s shaping their minds.
I think the fintech community is small yet large, if that makes sense. There is a lot of collaboration opportunity within it. There are some great networks, great conferences, and a lot of curious people.
Motivation and personal questions
Jason Thomas:
Obviously you’re in a very, very senior role. I guess it’s quite stressful. There must be easier roles out there. How do you stay excited in these type of roles? What keeps you motivated?
Willem:
It’s a great question. I think a lot of people in the industry who know me would say I’m a stickler for pain and a martyr – I like to go through the pain.
The reality is, I deeply care about it. Looking at Ecommpay, our purpose is to build inclusive payments processing platforms for merchants and their customers. That’s a purpose that is very well aligned to me.
I like to challenge the status quo. I’m never satisfied by just one thing – I always want to see what happens next. That gets me out of bed in the morning.
And then if I’m looking at it at a personal level, I’ve come from a family where my dad always challenged everything. He was never happy with one thing, he could always do things better. He was very entrepreneurial.
And I think that’s stayed with me. I always want to make sure my family has a better life. And for me, I do that for them.
Jason Thomas:
Brilliant. Love that answer.
If you weren’t in compliance, what would you be doing?
Willem:
I would love to be in music, and develop tools for musicians. Music is a great passion of mine. I play drums and guitar. I think without it I’d never really be able to escape.
Jason Thomas:
And you’re a big basketball fan, I’ve heard.
Willem:
I used to play it. When I lived in Belgium, I played in the Belgian league.
A long time ago now, obviously put on a few pounds.
But yeah, it’s something I still follow very closely. Big NBA fan.
Jason Thomas:
Who do you support?
Willem:
East and West Coast – East Coast, Boston Celtics. West Coast, LA Clippers.
Jason Thomas:
A couple of quick-fire questions, a little bit of fun. Would you say your morning routine is planned or chaotic?
Willem:
I’d say organised chaos is probably the right way.
It is structured to some degree. I know what time I need to wake up and all these things, but when you’ve got kids who need to go to school at the same time, and tubes, and all these kinds of things – thank God for having the capability of doing things on the mobile and the iPad nowadays. It makes it so much easier.
Jason Thomas:
Guilty pleasure – food, TV shows, podcast, anything?
Willem:
Food-wise, I love anything Malaysian. And chocolate – especially chocolate.
As for film, any kind of good horror movie. I love good horror movies. Anything that’s got a little bit of tension.
Jason Thomas:
Anyone in particular?
Willem:
One of my favourite movies is The Shining. Stanley Kubrick, I really like. A Clockwork Orange is one of my favourite books actually, from Anthony Burgess – one of my favourite books – but yes, Stanley Kubrick movies.
Jason Thomas:
And last question – if you could swap lives with anyone for a week?
Willem:
If it was music, and if he was still alive, it’d probably be John Bonham. He was the drummer of Led Zeppelin, my favourite band.
He was just the most incredible drummer out there. A jazz drummer that just played very hard. So if he was still alive and I had the opportunity to be someone that played back then, then it would be him.
Jason Thomas:
Well then, pleasure having you on.
Willem:
Thanks.
Jason Thomas:
Enjoyed talking to you.
Willem:
Thank you.
Outro:
That’s it for this episode of Making payments make sense.
This was a conversation worth sharing because it speaks directly to the pressures, trade-offs and decisions shaping compliance in fintech right now – from licensing and regulator engagement, to talent, AI, crypto and the evolving financial crime landscape.
If you enjoyed the episode, please subscribe to Making payments make sense for more sharp, practical conversations from across the world of payments.
Thanks for listening – and we’ll see you next time.
