September 24, 2025
This article presents general best practices on compliance in BaaS, focusing on reducing regulatory risks and protecting customers and partners. It does not constitute individualized legal, financial, or accounting advice, and should be used only as an informative reference. Strategic decisions should always consider risk assessment, the current regulatory context, and guidance from specialized professionals.
What is Banking as a Service (BaaS) and how does it work?
The Banking as a Service (BaaS) is a model that allows companies to launch financial products using the infrastructure of an authorized bank, without needing to build the entire banking operation from scratch. In practice, it's like “renting” the ready-made road to drive your car: you access systems, accounts, payments, and transfers without having to create all the asphalt.
The difference compared to traditional banks lies in the level of integration and flexibility. While banks offer standardized products to their end customers, BaaS enables fintechs, e-commerce, and other companies to customize financial services according to their business model, always supported by regulated partners.
Criterion | BaaS (Banking as a Service) | Traditional Bank |
Business model | Digital platform that offers banking infrastructure via APIs for companies | Financial institution that provides services directly to the end consumer |
Innovation | High flexibility and speed in creating new financial products | Slower innovation, dependent on rigid internal structures |
Technological integration | Open APIs allow rapid integration with applications and systems | Legacy systems, complex and inflexible integration |
Customer focus | Companies customize experiences for their users | Standardized model, with little customization |
Scalability | Grows according to demand, without the need for large physical investments | Growth limited by physical infrastructure and branch presence |
Operational costs | Slimmer, with a model based on technology | Higher, due to the maintenance of branches and traditional operations |
Compliance and regulation | Needs to operate via authorized partners (CVM, Bacen, Law 14.478/2022) | Already operates under direct regulation as a financial institution |
Time to launch products | Weeks or months, depending on integration with APIs | Months or years, due to bureaucracy and internal regulatory processes |
Competitive advantage | Speed, innovation, and customization | Stability, historical trust, and a consolidated network of clients |
Informative content. Does not constitute an offer of securities, currency exchange, or payment services. Past performance does not guarantee future results. Azify operates directly or through duly authorized partners, as per the scope. Evaluate risks, accounting, and tax impacts with your advisors.
Why is compliance essential in BaaS?
In the context of Banking as a Service (BaaS), compliance is not just a regulatory obligation: it is a strategic tool that reduces risks, strengthens the trust of customers and partners, and protects the business from legal and financial losses.
The main regulatory requirements include:
AML/CFT (Anti-Money Laundering and Combating the Financing of Terrorism): monitoring of transactions and identification of suspicious operations to prevent financial crimes.
KYC (Know Your Customer): rigorous due diligence to validate the identity and risk profile of the customer, ensuring the integrity of the platform.
LGPD (General Data Protection Law): adequate protection and handling of personal data, with responsibility in the collection, storage, and sharing of information.
Segregation of duties: clear separation of internal responsibilities to avoid conflicts of interest, fraud, or manipulation of critical processes.
Compliance failures can lead to significant consequences. In the case of LGPD, for example, the National Data Protection Authority (ANPD) imposed in 2023 its first fine, amounting to R$ 14,400.00, on a company that sold personal data without legal basis. Sanctions may include fines of up to 2% of the company's revenue, operational limitations, and damage to reputation, directly affecting the ability to secure partnerships and attract customers.
Therefore, a robust compliance program in BaaS not only keeps the company within the law but also strengthens credibility in the market and offers competitive security in a highly regulated sector.
What are the main regulatory risks in BaaS?
The BaaS environment involves multiple regulatory risks that must be managed carefully:
Money laundering and financing of terrorism (AML/CFT) – Digital financial operations can be targeted by illicit activities. Without constant monitoring and clear rules, partner institutions are exposed.
Data protection (LGPD) – BaaS deals with sensitive customer data. Leaks or misuse can result in penalties and harm market trust.
Failures in customer due diligence (KYC) – Failing to properly identify risky customers increases exposure to fraud and financial crimes.
How to reduce regulatory risks in BaaS?
Reducing regulatory risks in Banking as a Service (BaaS) requires a structured, ongoing approach supported by technology. Companies that implement good compliance practices can not only meet legal requirements but also increase the trust of clients and partners.
1. Establish clear internal compliance policies
Having well-defined rules is the first step to reducing risks. Essential points include:
Account opening and client onboarding: documented processes ensure that all stages comply with KYC and regulatory requirements.
Transaction limits and monitoring of suspicious activities: defining thresholds and automated alerts helps to quickly identify atypical behaviors.
Internal responsibilities and segregation of duties: each employee should have clear assignments to avoid conflicts of interest and concentrate responsibilities transparently.
Documented policies facilitate audits and show commitment to regulatory bodies, such as Bacen and CVM.
2. Continuously monitor and conduct periodic audits
Constant monitoring of operations is crucial to identify and correct failures before they become risks:
Real-time monitoring: allows detecting suspicious transactions and triggering immediate alerts.
Periodic audits: scheduled reviews ensure that processes and controls are being followed correctly and help improve internal policies.
3. Use technology for regulatory automation
Digital solutions transform compliance into a more agile, efficient, and reliable process:
Identity verification automation (KYC): speeds up onboarding and reduces manual errors.
Detection of suspicious patterns in transactions (AML/PLD/FT): intelligent systems identify anomalies on a large scale.
Report generation and audit trails: maintains robust compliance evidence ready for regulatory analysis.
The Brazilian fintechs, for instance, are adopting artificial intelligence to monitor thousands of transactions per minute, detecting inconsistencies before they become financial or legal risks.
Technology not only increases operational efficiency but also strengthens governance and demonstrates transparency to investors and regulatory bodies.
What are the success examples of compliance application in BaaS?
Companies that effectively apply compliance can:
Customer trust: users feel secure when using integrated financial services.
Ease of partnerships: banks and fintechs prefer to work with companies that demonstrate clear governance.
Safe growth: risk reduction allows expansion without compromising reputation or facing sanctions.
How compliance in BaaS generates tangible advantages for digital businesses:
Benefit | What does it enable? | What is the Practical impact? |
Reduction of legal risks | Following the regulations of Bacen, CVM, and Law 14.478/2022 minimizes fines and sanctions | Less exposure to regulatory actions and protection of the company's reputation |
Access to investors | Regulated companies convey trust and credibility | Facilitates fundraising from institutional and retail investors |
Operational efficiency | Automated processes for KYC, transaction monitoring, and audits | Reduction of manual errors, optimization of time and operational costs |
Transparency and traceability | Records of all transactions and documented decisions | Facilitates audits, regulatory reports, and market trust |
Improvement of internal governance | Clear policies, segregation of functions, and defined responsibilities | More organized organizational structure and more secure decisions |
Safe innovation | Allows the implementation of new digital financial products within the law | Launch of BaaS solutions quickly and reliably, with integrated compliance |
Relationship with partners | Demonstrates regulatory commitment to technology and financial partners | Facilitates strategic partnerships and secure API integrations |
What are the regulatory trends for BaaS?
The BaaS market follows national and international regulatory changes. In Brazil, laws such as Law 14.478/2022, guidelines from Bacen, CVM, and LGPD require BaaS providers to maintain strict controls and auditable records.
In the international scenario, there is increasing pressure for:
Greater transparency in cross-border operations.
Standardization of KYC/AML processes across digital platforms.
Integration of automated compliance controls.
Companies that anticipate changes and adjust processes reduce the risk of future sanctions and position themselves as a trusted reference in the market.
Informative content. Does not constitute an offer of securities, exchange or payment services. Past performance does not guarantee future results. Azify operates directly or through duly authorized partners, as per the scope. Assess risks, accounting and tax impacts with your advisors.
How to integrate compliance into the daily routine of a BaaS?
Best practices should be applied continuously and not just during the implementation phase:
Constant training: teams must understand internal policies and rules.
Segregation of duties: different areas handle onboarding, monitoring, and auditing to reduce the risks of conflict or fraud.
Periodic reporting: maintain detailed documentation for regulatory bodies and partners.
Support technology: monitoring systems, risk analysis, and automatic alerts.
Implementing good compliance practices in BaaS is essential to reduce regulatory risks, protect partner institutions, and ensure safety for customers. Internal policies, continuous monitoring, audits, and the use of technology are pillars that support secure and reliable operations.
