The Two Phases of any Compliance Program (And How To Know Which One You're In)

There are two phases of any compliance program implementation. They do not depend on your own knowledge and experience. They depend on the underlying processes, your teams, your tools and how you make decisions as a company.

Phase 01: BUILDING the Machine.

When I am the CCO  of the company in Phase 1, every day consists of non-stop meetings that always overrun, ongoing escalations for me to review customer messages or partner questions, late night slack exchanges and continuous sense of panic and chaos.  There is never enough time to think strategically. 

Phase 02: RUNNING the Machine.

THIS is the phase you were dreaming of when you first dreamed to be the compliance leader and have the full authority to decide what happens. There are problems, but you actually like solving these problems. You see progress. You like your team. And you enjoy your work.

But here’s the catch…

👉 If you don’t build Phase 01 the right way, how can you ever get to Phase 02?!

To keep it simple:

Your compliance program has two phases:

1. The phase where you build it.
2. The phase where you run it.

Phase 01 is tough.

It demands your time, energy, effort, and investments… As it should.

This is where most companies and many compliance officers give up. They can’t hack it. This is the ultimate test. When you survive this and move to Phase 2... there's an invisible Badge of Honor that only the others who have 'been there, done that' can see. 

But unfortunately, MOST compliance officers get stuck in this first phase.

And if you're here in Phase 01 now, you've probably asked yourself, 

“Is it always gonna be like this?”

The answer?

No.

(Well…not if you build Phase 01 right.)

Phase 01 is all about BUILDING your department, your team and your tools so you can eventually RUN your compliance program with far less time and effort.

You work less and you support more customers and open more doors for new business opportunities.

You can automate, delegate, or systemize it in Phase 02.

This is so hard for people to comprehend.

Well, sorry. Let me edit myself.

I actually think anyone reading this (including yourself) can find this very simple to comprehend…

…but it’s hard to actually IMPLEMENT this!

Why?

Because the old “employee mindset”  and “boomer” programs are playing out in the background.

“You have to work hard to be good enough, deserving, trustworthy, etc.”

So you just keep doing. Doing. Doing.

But here’s the real question:

Did you build reliable decision-making or risk-rating methodology?

A system?

A process?

…or did you just build a JOB for yourself? (Or more accurately, like 10 jobs for each members of your team?)

You’ll know the answer to this based on one simple test:

What happens to your business or your department when YOU YOURSELF stop working and stop checking emails and resolving issues?

Well, there’s your answer.

So let me help you with this a bit.

What You SHOULD Be Doing In Phase 01:

This is the Work That Pays You for Years

If you’re in Phase 01, your job is to build a machine that will eventually run without you.

Here’s a simple list of the right things to focus on, so you can graduate to Phase 02 FASTER.

✅1. Have a Complete, Deliverable Onboarding and Risk-Rating of customers that is  SCALABLE

This means you can onboard customers indefinitely, you have very little manual intervention, and your team can resolve all customer irregularities —without needing you.

It’s packaged. It’s ready. It’s plug-and-play.

✅ 2. Build Ongoing Monitoring that SAVES TIME, not WASTES TIME of your team on redundant alerts and false positives

You need one high-converting Transaction Monitoring System.

Build it. Test it. Tweak it. Optimize it.

(Again, building this will take time, but running it won’t…that’s Phase 02).

✅ 3. Create a Step-By-Step Documentation Process

You need a simple, repeatable system for generating and updating compliance documentation. The key word in that sentence being "repeatable."  

In fact, the more repeatable, the less effort it will inevitably take. 

The name of the game is consistent policy framework.

It means, when your partners or auditors or regulators ask for an explanation, it takes 3 minutes to find the right document.

You never have to start anything from scratch.

Have a process for how it gets created, edited, updated, reviewed and shared. Copy. Paste. Rinse. Repeat. 

And bonus points if you’re not the one doing it all.

✅ 4. Document Everything Below Your Pay Grade

If you’re the CCO answering customer support emails, reviewing customer’s documents or fiddling with tech ... at some point you have to stop and delegate.

Document it. Process-cize it. Especially the most repeatable tasks. This is why... Every PROCESS is YEARS of your life BACK.  Delegate. Automate. or... (and my favorite) DELETE IT!

What You SHOULD NOT Be Doing in Phase 01:

You're Not Scaling. You're Spinning.

Here’s where most people waste time, energy, and money…and stay stuck in Phase 01 forever.

❌ Creating Multiple Products or Services for Multiple Geographies at the Same Time

More services = more complex = more work = more time feeling stuck.

❌ Trying to Be Everywhere All at Once

You don’t need to be in all the conferences, regulatory groups and in all the meetings at the same time.

(Spreading yourself thin and trying to learn everything isn’t a strategy. It’s a plan for burnout.)

❌ Building processes that are  NOT Replicable and NOT Scalable

I’m talking about things like building too many manual workarounds, granting exceptions and hiring interns to fix fundamental things that do not work.

This shit is NOT a compliance program.

It’s bottom-feeding. And it ain't sustainable either.

What You SHOULD Be Doing in Phase 02:

You Built It. Now Run It Like a Business-Like CCO.

Once you’ve built the machine, Phase 02 is about letting it run—and scaling what works.

Here’s where your focus should shift:

✅ 1. Put Your Services in Front of More People

Stop creating more stuff or deploying random new risk-scoring systems.

You already have some tools and systems. Now? Turn up the volume.

Run it again. And again. And again.

Consistency beats reinvention every time.

✅ 2. Know Your Numbers and Run Compliance as a Profit Center.

As you’ve heard me say:

You can’t grow what you can’t measure.

Track your KPIs, cost of compliance per customer, fraud rates, dispute rates, conversion rates, customer activation rates.

Don’t just get more people IN... optimize what comes OUT. Optimize for customers who legitemately spend money with you.

✅ 3. Get as Much Off Your Plate as Humanly Possible

YOU ARE THE BOTTLENECK.

(Yes, even you.)

Delegate, automate, and release control.

“Control” is an illusion. Stop believing these lies that no one can do it as well as you can.

Spend more of your time on helping the people who are helping you. Coach them up. Improve their processes and workflows. Help them get more off THEIR plates!

✅ 4. Simplify. Remove Constraints.

Phase 02 is where you start getting better at doing less.

Focus on what drives results, and ditch the rest.

And again, get as much off your plate as possible.  

...ok, I’ll leave it there for now, hope this helps!

The Rise of the Digital CEO:

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More people leave the banking sector and want to work in FinTech and Crypto. Isn't that exciting?! 

Yet frankly, most are ill-equipped. They don't have the first clue how to run the FinTech compliance function (I know I didn't).

Yet, when you learn how to "clean up" your compliance dogma and manual processes and run compliance RIGHT, not only will your business grow with more efficient compliance function, but you'll get to work less... and enjoy it more. 

Check the full program and sign up to make sure you move from Phase 1 and Phase 2 ASAP.

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Remember, you don’t “have to do FinTech compliance”, you “get to do FinTech compliance” - so, let’s DO IT! Yana

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