From Rejection to Partnership: Banking Access for a Colombian Neobank

The Situation

A Colombian fintech focused on SME payments had been operating for 18 months using a single banking partner — a relationship that was increasingly strained by volume growth and escalating due diligence requests. Two additional banks had already blocked their account without a clear explanation.

The company had a functioning product, a growing customer base, and a real need for banking redundancy. What it lacked was a compliance posture that large Colombian financial institutions would accept.

What We Found

After a diagnostic review, we identified three material gaps:

1. Ownership transparency: The company's shareholder structure included holding companies without documented beneficial ownership chains, triggering alerts under Colombia's SARLAFT risk assessment frameworks.

2. AML policy gaps: Their internal AML/CFT policy had been drafted by a general counsel without virtual asset or fintech specialization. It was missing critical components, including a risk matrix, transaction monitoring procedures, and an independent effectiveness test.

3. Positioning in bank meetings: The team was presenting as a technology company rather than a regulated payments operator, which created unnecessary friction with bank compliance teams conditioned to evaluate financial institutions.

What We Did

Structural remediation (weeks 1–3)

We worked with the company's legal team to document the full beneficial ownership chain, register appropriate disclosures with Colombia's tax platforms, and prepared a corporate governance summary designed for bank due diligence review.

AML/CFT program rebuild (weeks 2–6)

We designed a SAGRILAFT-compliant AML/CFT policy suite including:

• Customer risk matrix (retail SME + high-risk segment rules)
• Transaction monitoring red flag list aligned to UIAF typologies
• KYC and enhanced due diligence procedures
• Independent effectiveness test conducted by a third party

Bank relationship strategy (weeks 4–8)

Rather than approaching banks cold, we leveraged existing relationships at tier-1 banks to arrange meetings at the right level — directly with compliance and product teams, rather than through standard commercial channels.

We prepared bank-specific information packages tailored to each institution's known risk appetite and compliance culture.

Results

Within 90 days of engagement start, the company had:

• Executed a framework agreement with a top tier for fund dispersion
• Opened a secondary account with another top tier bank for collections
• Received conditional approval from a third bank pending a 60-day monitoring period

The company now operates with three independent banking channels, reducing concentration risk and enabling product expansion into new customer segments.

This case study reflects the general nature of the engagement. Specific client details have been anonymized.