Field notes · 02 April 2026
What Taiwan fintech teams forget in a licensing evidence pack
Filing narratives often outrun the customer files. Here is what we check before an FSC conversation becomes awkward.
A licensing readiness review is less about elegant policy prose and more about whether a random customer file matches the story in the application. Taiwan fintech teams preparing an FSC filing often under-invest in that match.
Policies that never reach the floor
We regularly find onboarding manuals that describe dual review for high-risk customers while the live queue shows single approval under volume pressure. Examiners notice when timestamps and user IDs cannot support the dual-review claim. Updating the manual after sampling starts does not repair the historical gap.
Training logs without attendance meaning
Attendance sheets signed in bulk, or e-learning completions with no assessment record, weaken the training narrative. We prefer short quizzes or supervisor sign-off tied to role changes — something that shows a person actually absorbed the rule they are meant to apply.
Ownership charts that stop at titles
Key-person tables that list titles without deputies create a single point of failure on paper. If the AML officer is also the only person who can export monitoring alerts, the packing list should say so honestly and describe cover arrangements.
A useful pre-filing habit
Two weeks before submission, pull twenty files at random and ask a colleague who did not build the pack to match each file to the policy section it supposedly proves. The files that stall that exercise are the ones that deserve attention before anyone else reads them.