Consulting & Advisory

Custom Solution Architecture for Regulated Fintech

We design the technical and operational architecture behind your regulated product — built to be commercially viable and defensible in front of a regulator.

Overview

A payment, e-money, or crypto business lives or dies on its architecture. The flow of funds, the ledger model, the choice of BaaS partner or direct scheme access, and the way KYC, AML, and security controls are wired together determine not only whether the product works, but whether it can be licensed, audited, and scaled. SKY7 designs that architecture end to end — translating your commercial model and chosen jurisdiction into a concrete, documented blueprint that engineers can build and supervisors can scrutinise. We sit between your product, your legal and compliance obligations, and the providers who will ultimately power the rails, so the system you build is the system you can defend.

01

Flow-of-funds design

The flow of funds is the spine of any regulated payment or e-money business, and it is the first thing a regulator will examine. We map every leg of the money movement — pay-in, settlement, holding, conversion, and pay-out — and define who holds client funds at each point, on what legal basis, and through which account.

For e-money and payment institutions this means designing safeguarding correctly from the outset: segregated client-money accounts, safeguarding reconciliation, and a clear separation between client funds and the firm's own capital. For crypto and VASP models, it means clarity on custody, on- and off-ramp routing, and where fiat and digital assets touch. The result is a flow that is commercially efficient and consistent with the conduct and prudential rules of your target jurisdiction.

02

Ledger and account model

Behind every clean user experience sits a ledger that must be internally consistent, reconcilable, and auditable. We design the account and ledger model that records each movement — client balances, fee accruals, FX positions, settlement obligations, and safeguarding postings — so that the books reconcile to the penny and to the underlying bank and scheme records.

We specify whether you operate a single-currency or multi-currency ledger, how sub-accounts and virtual IBANs are represented, how double-entry integrity is enforced, and how the ledger supports the regulatory reporting and reconciliation you will be required to produce. This is the layer that makes audits routine rather than painful.

03

Integrations: BaaS, processors, and vendors

Few regulated fintechs build every rail themselves. The architecture typically stitches together a banking-as-a-service or sponsor-bank partner, card processors and scheme connections, payment gateways, FX and treasury providers, and a stack of KYC, AML screening, and transaction-monitoring vendors. The way these are integrated has direct regulatory weight — outsourcing and third-party risk are squarely within a supervisor's remit.

We design the integration topology: which functions are insourced versus outsourced, where the regulated boundary sits, how data and instructions pass between systems, and how you retain control and oversight of critical providers. We also help you select vendors that fit your jurisdiction, your volumes, and your licence perimeter, so the partnerships you sign support the application rather than complicate it.

04

Data and security posture

Regulated financial firms are held to a high bar on information security, operational resilience, and data protection. We define the security posture that the rest of the architecture must satisfy: data classification and residency, encryption in transit and at rest, key management, access control and segregation of duties, logging and audit trails, and the resilience and continuity arrangements expected of a regulated entity.

Where card data is in scope, we account for PCI DSS obligations; where personal data is processed, we design for GDPR and equivalent regimes. The posture is documented in a way that maps cleanly onto the ICT, operational-resilience, and outsourcing expectations supervisors increasingly apply across the EU, UK, and beyond.

05

Regulator-defensible by design

A clever architecture that cannot be explained to a supervisor is a liability. Everything we design is built to be defended — in a licence application, in a regulator's questions, and in subsequent audits and inspections.

That means the flow of funds, the safeguarding model, the outsourcing arrangements, and the control framework are not only sound but documented in the language and structure regulators expect. The architecture aligns to the specific licence you are pursuing — payment institution, e-money institution, VASP or crypto authorisation, or another permission — so that what you build and what you apply for are one and the same. This is where our regulatory and technical sides meet, and it is what separates an architecture that ships from one that also gets authorised.

06

Commercially viable, not just compliant

Defensibility is necessary but not sufficient. The architecture also has to make commercial sense — to support your unit economics, your roadmap, and your growth across markets. We design with cost, latency, settlement speed, and provider economics in mind, avoiding over-engineering on one side and brittle shortcuts on the other.

We pressure-test the design against your business plan: the volumes you expect, the corridors and currencies you will serve, the products you intend to add, and the jurisdictions you may expand into. The goal is an architecture that is right for where you are today and extensible to where you intend to be, without a costly re-platform the moment you scale.

How we work and what you receive

We typically begin with a structured discovery of your commercial model, target jurisdiction, and licence intentions, then produce an architecture blueprint your team and ours can act on. Deliverables generally include a documented flow-of-funds and safeguarding model, a ledger and account specification, an integration and outsourcing map, a data and security posture, and the supporting narrative that feeds directly into a licence application.

Because SKY7 also handles licensing, entity setup, and ongoing compliance across 46 jurisdictions, the architecture does not sit in isolation — it connects to the application, the operating model, and the providers that will run it. Engagements are scoped to your stage, whether you need a greenfield design, a second opinion on an existing build, or a remediation of an architecture that has outgrown its original assumptions.

FAQ

Frequently asked questions

How is this different from hiring a software architect or a development agency?

A general software architect optimises for engineering quality; they rarely design for safeguarding rules, outsourcing requirements, or what a financial supervisor will accept. We work at the intersection of technology and regulation, so the architecture is engineered to be built and authorised. Because SKY7 also handles the licensing and compliance, the design is informed by what your specific application will need to demonstrate.

Do you build the system, or only design it?

Our focus is the architecture — the blueprint, specifications, and documentation your engineering team or chosen providers implement. We can work alongside your developers and your BaaS, processing, and compliance vendors during the build to keep the implementation faithful to the design, but we are not positioning this as a code-delivery service.

We already have a product live. Can you still help?

Yes. A common engagement is reviewing an existing architecture ahead of a licence application, a new market entry, or a scaling event — identifying where the flow of funds, safeguarding, ledger, or outsourcing arrangements would not stand up to regulatory scrutiny, and designing the remediation. It is far cheaper to correct this before a supervisor or auditor finds it.

Which jurisdictions and licence types do you design for?

We work across 46 jurisdictions spanning the EU and EEA, the UK, Switzerland, the UAE, and selected offshore centres, and across payment institution, e-money, VASP and crypto, and related permissions. The architecture is shaped by your specific target jurisdiction and licence, because the safeguarding, outsourcing, and conduct expectations differ meaningfully between them.

Will this architecture guarantee we get licensed?

No responsible adviser can guarantee a regulatory outcome, and we will not. What we can do is materially improve your position by ensuring the technical and operational design is sound, well documented, and aligned to the expectations of your chosen regulator — so that architecture is a strength of your application rather than a source of objections.

Get started

Design an architecture you can build and defend

Talk to SKY7 about your product, your target jurisdiction, and the licence you intend to pursue. We will help you turn your commercial model into an architecture that engineers can ship and regulators can accept.

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