‘Kostelijk noted that banks are often responsible for regulatory compliance on behalf of their partners, even when those partners aren’t held to the same standards. This creates a “complex situation”, especially in outsourcing arrangements, where banks may face additional dependencies and risk management responsibilities. She advised banks against linking to “whatever the partner in whatever shape or form is doing”, warning that in a heavily regulated environment, a fintech partner with lax compliance standards could bring regulatory scrutiny onto the bank. “[The regulator] then will call upon us banks to say, well, you referred your customers to this company, you solve it,” Kostelijk stated, emphasising the need for carefully structured “outsourcing” models. Manish Kohli, Head of HSBC’s Global Payments Solutions, added that for banks with the right controls in place, the regulatory environment can actually serve as a “big tailwind towards fintech and bank collaboration”. Partnerships with fintechs, he noted, allow banks to bring new solutions to market faster while upholding regulatory priorities.’