How often should a fintech compliance checklist be reviewed?

At minimum, review quarterly and before any major product launch, market expansion, or significant feature change. Regulatory requirements shift regularly. The OCC and FinCEN publish guidance updates throughout the year, and state regulators may change licensing requirements with limited notice. Build compliance reviews into your quarterly planning cadence rather than treating them as ad-hoc tasks.

Who owns the compliance checklist in a product team?

The product manager typically owns the checklist as a coordination tool, but the actual compliance obligations are owned by specific functional leads. Legal owns regulatory interpretation, security owns technical controls, and engineering owns implementation. The PM's role is to ensure nothing falls through the cracks and that compliance work is prioritized alongside feature work. Use your [product strategy](/strategy-guide) planning process to allocate capacity for compliance work each quarter.

What is the difference between PCI DSS and SOC 2?

PCI DSS is a specific standard for organizations that handle payment card data. It prescribes detailed technical controls (encryption methods, access rules, scanning frequency). SOC 2 is a broader audit framework covering security, availability, processing integrity, confidentiality, and privacy. Many fintech companies need both: PCI DSS for payment processing and SOC 2 Type II for customer trust and enterprise sales. They overlap in areas like access control and encryption, but PCI DSS is more prescriptive about cardholder data specifically.

Do I need a compliance checklist if we use a payment processor like Stripe?

Yes, but your scope is significantly reduced. Using Stripe or a similar processor means you may qualify for PCI DSS SAQ-A (the simplest self-assessment) instead of a full assessment. However, you still have obligations around data protection, AML (if you hold funds or facilitate transfers), and any product-specific regulations like lending laws. The checklist helps you track what Stripe covers versus what remains your responsibility. Review Stripe's [shared responsibility model](https://stripe.com/docs/security/guide) as a starting point.

How do I handle compliance when expanding to new markets?

Start with a regulatory gap analysis 3-6 months before launch. Identify what licenses, registrations, or approvals are required in the new jurisdiction. Map the new requirements against your existing checklist to find gaps. Common pitfalls: assuming US compliance covers Canada (it does not), underestimating EU data residency requirements, and missing state-level licensing in the US. Budget both time and legal fees. License applications can take 6-18 months depending on the state or country. ---

Fintech Compliance Checklist Template

What This Template Is For

Building fintech products without a structured compliance process is like driving without brakes. It works until it does not. Regulatory requirements span multiple domains: data protection, payment security, anti-money laundering, and consumer lending laws. Missing a single requirement can result in fines, license revocation, or forced product shutdowns.

This checklist template gives fintech product managers a structured way to track regulatory obligations across the most common compliance frameworks. It is designed to be filled out collaboratively with your legal, security, and engineering teams. Each section maps to a specific regulation, with checkboxes for individual requirements and fields for evidence and ownership. Use it alongside your product risk assessment to ensure nothing falls through the cracks.

For a deeper dive into how technical PMs manage cross-functional requirements like these, see the Technical PM Handbook.

How to Use This Template

Copy the checklist into your team's compliance tracking system (Notion, Confluence, or a spreadsheet).
Work with your legal counsel to identify which regulations apply to your product and jurisdiction.
Delete sections that do not apply. Add any jurisdiction-specific requirements your counsel identifies.
Assign an owner to each checklist item. Compliance is a team sport, not a PM solo mission.
For each item, document the evidence that proves compliance (audit logs, certifications, policies, test results).
Review the checklist quarterly and before every major product launch or market expansion.

The Template

Regulation Applicability Assessment

Regulation	Applies?	Jurisdiction
PCI DSS	Yes / No / Partial	[Markets]
PSD2 / Open Banking	Yes / No	[EU/UK markets]
SOX (Sarbanes-Oxley)	Yes / No	[US public companies]
GDPR / CCPA	Yes / No	[Applicable regions]
BSA / AML	Yes / No	[US markets]
State Money Transmitter Licenses	Yes / No	[US states]
TILA / Reg Z (Lending)	Yes / No	[US lending products]

PCI DSS Compliance

☐ Cardholder data environment (CDE) scope documented and reviewed
☐ Network segmentation in place to isolate CDE from other systems
☐ Encryption of cardholder data at rest (AES-256 or equivalent)
☐ Encryption of cardholder data in transit (TLS 1.2+)
☐ Access to CDE restricted to authorized personnel only
☐ Unique user IDs assigned to every person with computer access
☐ Vulnerability scanning performed quarterly by approved scanning vendor (ASV)
☐ Penetration testing performed annually
☐ Security incident response plan documented and tested
☐ PCI DSS Self-Assessment Questionnaire (SAQ) completed for current year
☐ Attestation of Compliance (AOC) on file

Owner: [Name]

Last Audit Date: [Date]

Evidence Location: [Link to audit report or certification]

☐ Data processing inventory completed (what data, where stored, who accesses)
☐ Lawful basis for processing documented for each data category
☐ Privacy policy updated and accessible to users
☐ Cookie consent mechanism implemented (opt-in for EU, opt-out for CA)
☐ Data subject access request (DSAR) process documented and tested
☐ Data retention policy defined and automated where possible
☐ Data Processing Agreements (DPAs) signed with all sub-processors
☐ Data Protection Impact Assessment (DPIA) completed for high-risk processing
☐ Breach notification process documented (72-hour GDPR window)
☐ Right to deletion (erasure) process implemented and tested

Data Protection Officer: [Name or N/A]

Last Review Date: [Date]

Anti-Money Laundering (AML / BSA)

☐ AML compliance program documented and board-approved
☐ Customer Identification Program (CIP) implemented
☐ Customer Due Diligence (CDD) procedures in place
☐ Enhanced Due Diligence (EDD) triggers defined for high-risk customers
☐ Sanctions screening against OFAC, EU, and UN lists integrated
☐ Suspicious Activity Report (SAR) filing process documented
☐ Currency Transaction Report (CTR) filing for transactions over $10,000
☐ AML training completed for all relevant staff (annual)
☐ Independent AML audit conducted within last 12 months
☐ Transaction monitoring rules configured and reviewed quarterly

BSA Officer: [Name]

Last Independent Audit: [Date]

Payment Services (PSD2 / Open Banking)

☐ Strong Customer Authentication (SCA) implemented for in-scope transactions
☐ SCA exemption logic documented (low-value, trusted beneficiary, TRA)
☐ Open Banking APIs meet regulatory technical standards (Berlin Group / OBIE)
☐ Third-party provider (TPP) verification process in place
☐ Transaction risk analysis (TRA) model validated
☐ Fallback authentication mechanism available if primary SCA fails
☐ Consumer dispute resolution process documented
☐ Regulatory reporting obligations identified and automated

Compliance Lead: [Name]

Next Review: [Date]

Licensing and Registration

☐ Required licenses identified for each operating jurisdiction
☐ Money transmitter licenses obtained for applicable US states
☐ E-money license or payment institution authorization obtained (EU/UK)
☐ License renewal dates tracked and calendared
☐ Surety bond or net worth requirements met
☐ State examination reports addressed (findings remediated)
☐ Agent/partner registrations completed where required

Licensing Counsel: [Name]

License Tracker Location: [Link]

Quarterly Compliance Review Checklist

☐ All checklist sections reviewed with legal counsel
☐ New regulations or guidance notes assessed for impact
☐ Audit findings from previous quarter remediated
☐ Staff training records up to date
☐ Third-party vendor compliance certifications current
☐ Board or leadership compliance report delivered

Filled Example: Digital Wallet Product

Regulation Applicability Assessment

Regulation	Applies?	Jurisdiction	Notes
PCI DSS	Yes	Global	Level 1 merchant (>6M transactions/year)
PSD2 / Open Banking	Yes	EU, UK	Payment initiation and account info services
SOX	No	N/A	Private company
GDPR / CCPA	Yes	EU, California	Users in 14 EU countries and California
BSA / AML	Yes	US	FinCEN-registered MSB
State MTLs	Yes	US (47 states)	Licenses held in 38 states, 9 pending
TILA / Reg Z	No	N/A	No lending features in scope

PCI DSS (Excerpt)

☑ Cardholder data environment scope documented. Last review: January 2026.
☑ Network segmentation validated by QSA in annual assessment.
☑ AES-256 encryption at rest. Key rotation every 90 days.
☑ TLS 1.3 enforced on all external endpoints.
☑ CDE access restricted to 12 named engineers via VPN + MFA.
☐ Q1 2026 ASV scan scheduled for March 15. Previous scan: December 2025 (pass).

AML (Excerpt)

☑ CIP collects government ID + selfie verification via Jumio.
☑ CDD tiering: Basic (< $1,000/month), Standard ($1,000-$10,000), Enhanced (> $10,000).
☑ OFAC screening at onboarding and daily batch re-screening.
☑ SAR filing: 14 SARs filed in Q4 2025. Average filing time: 6 business days.
☐ Independent AML audit due by April 30, 2026 (RFP sent to three firms).

Key Takeaways

Regulatory compliance is not optional in fintech. A structured checklist prevents costly gaps
Assign clear owners to every compliance item. Shared responsibility often means no one is responsible
Review quarterly and before major product changes, not just at annual audit time
Using a payment processor reduces but does not eliminate your compliance obligations
Start market expansion compliance work 3-6 months before planned launch

About This Template

Created by: Tim Adair

Last Updated: 3/4/2026

Version: 1.0.0

License: Free for personal and commercial use

Fintech Compliance Checklist Template