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Licensing and Authorization Process for Non-Bank Financial Entities

Financial Regulation and Operational Excellence November 30, 2025
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Introduction

The **Licensing and Authorization Process** is the gateway through which regulators maintain the integrity, stability, and public confidence in the Non-Bank Financial Institution (NBFI) sector. This course provides a structured, detailed guide to designing and executing a rigorous, risk-based licensing regime for diverse non-bank entities. Participants will learn how to assess the applicant's fit and proper status, scrutinize their business plans, verify capital adequacy, and evaluate the integrity of their proposed internal controls (AML/KYC, governance). The program emphasizes the use of the licensing process as the first, critical step in the Risk-Based Supervision (RBS) life cycle, setting clear expectations for prudence and compliance from inception.

Objectives

Upon completion of this course, participants will be able to:

  • Design a clear, **risk-tiered licensing framework** with tailored requirements for different categories of non-bank financial entities (e.g., finance, leasing, MSBs).
  • Establish and apply rigorous criteria for assessing the **"fit and proper" status** and track record of the applicant's owners, directors, and senior management.
  • Scrutinize and critically evaluate an applicant's **business plan, financial projections, and capital adequacy** under stress scenarios.
  • Develop a comprehensive checklist for assessing the adequacy of the applicant's proposed **governance, risk management, and internal control frameworks** (including AML/KYC).
  • Manage the entire licensing lifecycle, from pre-application engagement and document review to final decision and post-authorization monitoring.
  • Understand the legal and procedural requirements for transparency, due process, and the formal communication of licensing decisions.
  • Formulate policy on setting initial **minimum capital requirements** and calculating operational risk capital for non-deposit-taking institutions.
  • Use the licensing review to establish the initial **risk rating** that will feed into the ongoing supervisory process (RBS).

Target Audience

  • Licensing and Authorization Managers and Analysts at Regulatory Authorities.
  • Prudential and AML/CFT Supervisors (for input into the review).
  • Legal Counsel specializing in Regulatory Applications and Administrative Law.
  • Compliance and Strategy Officers at Entities Seeking NBFI Licenses.
  • Regulatory Policy Developers and Economists.

Methodology

  • "Fit and Proper" Assessment Case Studies and Role-Playing Exercises
  • Workshops on Scrutinizing NBFI Business Plans and Financial Projections under Stress
  • Group Activities on Developing a Governance and Control Framework Checklist for a New License Applicant
  • Expert Lectures on Administrative Law and Due Process in Licensing Decisions
  • Workshops on Calculating Minimum Initial Capital Requirements for NBFIs
  • Individual Exercises on Documenting and Justifying a Conditional Licensing Decision

Personal Impact

  • Development of specialized expertise in designing and executing rigorous, risk-based licensing processes.
  • Enhanced ability to apply "fit and proper" criteria and scrutinize complex business and financial plans.
  • Improved strategic understanding of the licensing phase as a critical component of the RBS lifecycle.
  • Acquisition of valuable skills in legal documentation, due process, and communicating regulatory decisions.
  • Increased professional credibility as a certified expert in financial sector gatekeeping.
  • Better decision-making that ensures only sound, well-governed institutions enter the market.

Organizational Impact

  • Significant strengthening of the **integrity and stability** of the non-bank financial sector from market entry.
  • Reduced risk of institution failure and illicit finance activity through rigorous upfront scrutiny.
  • Establishment of clear, consistent, and legally defensible **licensing standards and procedures**.
  • Improved quality of governance, risk management, and compliance controls in newly authorized entities.
  • Better foundation for the ongoing **Risk-Based Supervision (RBS)** process.
  • Enhanced public confidence in the regulated status of non-bank financial services.

Course Outline

Unit 1: Licensing as the Gateway to Supervision

First Line of Defense:
  • The policy objectives of the licensing process: integrity, stability, consumer protection, competition.
  • Defining the legal and operational thresholds that trigger the need for a non-bank license.
  • Structuring the licensing function within the regulatory authority and coordinating with supervision teams.
  • Review of international best practices for licensing non-bank and specialized financial institutions.
  • The importance of transparency, timelines, and predictability in the application process.

Unit 2: The Assessment of Fit and Proper Status

Integrity of Leadership:
  • Establishing clear, objective criteria for assessing the **"fit and proper"** status of owners, directors, and senior management.
  • Protocols for conducting background checks, due diligence, and verifying the track record of applicants.
  • Managing the assessment of ownership structure, beneficial ownership, and potential conflicts of interest.
  • The process for conducting competency interviews and evaluating the proposed organizational structure.
  • Legal requirements and procedural fairness in communicating adverse findings on fit and proper status.

Unit 3: Financial Projections and Business Plan Scrutiny

Sustainability and Risk:
  • Developing a template for the required **business plan** and key focus areas for regulatory review.
  • Critical assessment of financial projections, revenue models, and operational viability over a multi-year horizon.
  • Protocols for verifying the source of initial **capital** and its adequacy relative to the proposed business risks.
  • Applying stress tests to the financial model to assess resilience under adverse market conditions.
  • Analyzing the potential for the business plan to introduce new systemic or illicit finance risks.

Unit 4: Control and Governance Framework Review

Operational Integrity:
  • Evaluating the proposed **corporate governance** structure (Board composition, committees, independence) against best practice.
  • Assessing the adequacy of the proposed **Risk Management Framework** and the independence of the risk function.
  • Detailed review of the applicant's proposed **AML/KYC compliance program** and IT infrastructure controls.
  • Protocols for reviewing internal audit arrangements, outsourcing plans, and segregation of duties.
  • Ensuring the technology and IT systems are robust, scalable, and secure for the proposed activities.

Unit 5: Decision Making and Post-Authorization

Transition to RBS:
  • The formal process for the final licensing decision: committee review, board approval, and legal documentation.
  • Protocols for communicating the decision (approval, conditional approval, or rejection) and managing appeals.
  • Developing the initial **Risk-Based Supervision (RBS) profile** and risk rating based on the licensing review findings.
  • Establishing mandatory post-authorization monitoring requirements (e.g., meeting capital targets, implementing remaining controls).
  • The role of the license in facilitating access to market utilities and payment systems.

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Upcoming Sessions

23 Feb

Dubai

February 23, 2026 - February 27, 2026

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16 Mar

Geneva

March 16, 2026 - March 20, 2026

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