independent professional advice before acting on any information contained Receiving Your Licence Is Only the Beginning
For many firms, obtaining a forex licence feels like crossing the finish line.
In reality, it marks the beginning of a far more challenging phase.
Regulators assess applicants based on their proposed business model. Once the licence is issued, the focus shifts to something entirely different: demonstrating that the firm is capable of operating safely, compliantly and sustainably.
The first 90 days after licensing often determine whether a newly authorised firm transitions smoothly into operations or encounters delays with banking, service providers, regulatory filings and the whole activation process.
At FiveComply, we have supported numerous regulated financial institutions through this transition. One consistent observation is that firms often underestimate the amount of work that follows licence approval.
1. Regulatory Approval Must Become Operational Reality
A licence authorises a business to operate but it does not make it operational overnight.
During the first few months, firms typically need to:
- open bank accounts
- fund minimum regulatory capital
- arrange professional indemnity insurance where required
- finalise agreements with local service providers
- complete corporate filings
- implement governance arrangements
These are often conditions that must be satisfied before full business operations commence.
2. Your Compliance Framework Must Become “Live”
One of the biggest misconceptions is that AML and compliance become relevant only after clients begin trading.
In reality, regulators expect firms to have fully operational compliance systems before onboarding their first customer.
This includes:
- AML/CFT procedures
- Customer Due Diligence (CDD)
- sanctions screening
- risk assessment methodology
- complaints handling procedures
- conflicts of interest management
- record retention
- internal governance
Policies sitting on a shelf are rarely sufficient. Regulators increasingly expect firms to demonstrate that these controls are functioning in practice.
3. Building the Operational Ecosystem
A licensed broker depends on far more than a trading platform.
Successful launches require coordination between multiple providers, including:
- banking partners
- payment providers
- liquidity providers
- trading platform providers
- CRM systems
- KYC verification providers
- screening software
- hosting and cybersecurity providers
- outsourced compliance and audit providers
Many projects are delayed simply because these relationships are not established early enough.
4. Governance Must Be Evidenced
Corporate governance begins immediately after licensing.
Examples include:
- holding the first Board meeting
- approving operational policies
- adopting client documentation
- approving outsourcing arrangements
- documenting key business decisions
- defining reporting lines
These governance records often become some of the first documents requested during regulatory inspections.
5. Your Brand Must Be Ready for Regulatory Scrutiny
Many firms focus on launching their website quickly.
However, regulators increasingly review:
- website disclosures
- legal documentation
- risk warnings
- client agreements
- privacy notices
- marketing material
- domain ownership
- trademark protection
Marketing that is inconsistent with the scope of the licence can create regulatory concerns from the outset.
6. Client Onboarding Is More Than Opening Accounts
Before accepting clients, firms should ensure they have clearly documented:
- onboarding workflows
- KYC responsibilities
- source of funds verification
- sanctions screening
- client risk classification
- ongoing monitoring procedures
- transaction reporting processes
The first client often tests whether internal procedures actually work in practice.
7. Reporting Obligations Begin Earlier Than Many Expect
Newly licensed firms frequently assume reporting only starts once they become profitable.
In reality, many jurisdictions require firms to maintain ongoing compliance from the first day of authorisation, including:
- capital adequacy monitoring
- regulatory notifications
- AML registrations
- CRS/FATCA registrations
- annual audits
- compliance certifications
- board reporting
- periodic regulatory returns
Missing an early filing can quickly attract unnecessary regulatory attention.
8. Operational Resilience Should Not Be an Afterthought
Today’s regulators expect firms to prepare for disruption.
This includes:
- disaster recovery planning
- business continuity arrangements
- cybersecurity measures
- secure data storage
- staff training
- outsourced provider oversight
Operational resilience is increasingly viewed as part of sound governance rather than an optional IT exercise.
Common Mistakes During the First 90 Days
Some of the most common issues we encounter include:
- Delaying bank account activation.
- Waiting too long to engage liquidity and payment providers.
- Treating compliance manuals as paperwork rather than operational tools.
- Launching a website before legal and regulatory reviews are completed.
- Underestimating governance documentation.
- Missing initial regulatory registrations and reporting deadlines.
- Failing to document internal decision-making.
- Assuming post-licensing support is no longer required.
Why Post-Licensing Support Matters
The licensing process demonstrates that a business can meet regulatory entry requirements.
The first 90 days demonstrate whether it can operate as a regulated financial institution.
At FiveComply, we support firms beyond licence approval by assisting with operational activation, governance implementation, compliance framework deployment, regulatory registrations, provider coordination and ongoing compliance support. Our objective is to help firms move from being licensed to being fully operational while meeting regulatory expectations from day one.
Disclaimer: This article is provided for general informational purposes only and does not constitute legal, regulatory, tax, or professional advice. Readers should seek herein.
