When Michiel Hoogenboom of Cense and Peter Engering of Compliance Champs sat down for coffee after months of conversations with banks, regulators and technology providers across Europe, one theme kept resurfacing. Crypto-assets are moving into the core of financial infrastructure, into payments, settlement, tokenisation and institutional finance. The compliance model that grew up alongside traditional banking, the model that places compliance at the end of the line, will not survive the move.
Speed changes the equation
Stablecoins are forcing the issue to be addressed. With MiCAR now in force across the European Union (EU), the debate inside banks has shifted from whether they can engage with crypto-assets to how they operate in an always-on financial system. Money moves in seconds through infrastructure that never pauses. Treasury operations, liquidity management and wholesale settlement all begin to change when markets operate continuously.
Banks were designed for something different. Office hours, batch processing and settlement delays were more than operational features. It provided the time in which compliance could review transactions, assess clients and escalate concerns. Tokenisation is now applying the same pressure across a widening range of assets. For Hoogenboom, the defining question is no longer whether banks adapt to a 24/7 financial economy, but how.
Automation is part of the answer. Manual controls cannot keep pace with instant settlement, and Engering expects responsibly governed AI to absorb much of the routine work, leaving people to focus on the final decisions and the cases that genuinely require judgement. But speed alone solves nothing, because this faster tool bolted onto a process that runs after the fact still arrives after the fact.
Designed in, not bolted on
The deeper change is architectural. Compliance by design means controls that live inside the transaction flow itself: screening at initiation rather than review after settlement, regulatory logic written into systems as code, monitoring that travels with the asset instead of chasing it.
The idea has a useful precedent. Privacy by design began as a principle and ended up in the GDPR as a binding obligation. We expect compliance in the crypto-asset economy to follow the same road, from good practice to supervisory expectation to legal requirement. Institutions that move early will find the transition manageable. Those that wait will be retrofitting under pressure, at retrofit prices.
For boards, the challenge is that this transition is unlikely to arrive through a single regulatory event. It will happen gradually, as tokenised assets, new payment rails and digital settlement become commercially attractive. That makes delay deceptively comfortable. By the time compliance becomes the bottleneck, the technology and operating model that created it may already be deeply embedded.
Data and people come first
None of this is primarily a technology purchase. It rests on reliable data and on people who know what to do with it, and Engering is direct about the second part. Institutions should invest in structured, continuous education covering AI, prompting, source criticism, data privacy and the disciplined use of company data, a subject he regards as business-critical.
“The bank with the best data wins. Data quality becomes central because AI, robotic process automation and automated compliance all depend on reliable data.”
Peter Engering
No one builds this alone
Engering is sceptical of the idea that one firm can solve everything for a large institution. Compliance Champs exists, he notes, because it chose to “focus on a niche and become very good at it… one organisation cannot realistically solve all compliance challenges by itself.” Banks cannot juggle thousands of vendors either, so specialists will matter most where the technology or the expertise is genuinely scarce. He also sees banks acquiring specialist suppliers to bring expertise and intellectual property in-house.
“My advice to CEOs, CCOs and boards would be to invest in talent. Organisations are continuously downsizing, but they need to recognise talent, give people room to make mistakes and give them room to grow.”
Peter Engering
Five years out
By the early 2030s, Hoogenboom expects crypto-assets to become so commonplace that consumers stop noticing, or caring, whether a transaction is settled in fiat money or stablecoins. Getting there asks something of the incumbents: “Be curious, trust in the role you have played, but be humble enough to adapt to new times, and that means a willingness to redesign compliance for the crypto-asset economy.”
Engering’s hope is that financial crime in crypto stops being the dominant story. That will only happen, in his view, if controls mature to the point where crime becomes genuinely hard work. Which is precisely what designing compliance is for.
From control to design
The shift both men keep returning to is one of mindset as much as technology: from compliance by control to compliance by design. Get it right and compliance stops being the department that says no at the end of the process. Instead, it becomes part of the architecture that allows products, payments and crypto-assets to move safely through an always-on financial system.
For decades, compliance has had to keep pace with financial innovation. Crypto-assets may reverse that relationship. Innovation will increasingly depend on whether compliance has been designed into the system from the outset, rather than added once the technology is already live.
Every bank is likely to redesign compliance for the crypto-asset economy eventually. The real question is whether it happens deliberately, as part of a long-term strategy, or reactively, under commercial and regulatory pressure.
Because in an always-on financial system, there is no end of the line. Compliance has to become part of the line itself.
Compliance by design starts with the right partners. Start the conversation with Compliance Champs and Cense.
There was also recently podcast recording between Hugo Leijtens and Peter of Compliance Champs. It can be viewed here.
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