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When a Citizenship Scheme Collides with Payment Reality
The EU Court just ruled Malta’s citizenship-for-investment scheme illegal, and we just have to wait and see if every client file tied to a Maltese setup now has to be re-checked again.
This change will definitely have an effect on how international clients structure their operations, how banks respond to nationality claims in the future, and how onboarding logic needs to be written going forward.
All banks and payment providers now have to be brought up to date, their risk profiles need to be reviewed, and the old thinking that allowed these clients through without proper checks must be replaced with a more serious and current approach.
What was once a fast track can now raise red flags. If your account, SEPA access, or license was built on this structure, you could be in trouble.
Read my article for more information: https://www.linkedin.com/pulse/when-citizenship-scheme-collides-payment-reality-viktoria-soltesz-pfu8e/
If you hear about OFAC’s new 10-year recordkeeping rule today, it’s already too late and you are in risk.
Starting 21 March 2025, anyone subject to U.S. sanctions laws—including non-U.S. firms. If your business touches U.S. dollars, U.S. infrastructure, U.S.-owned entities, or sanctioned jurisdictions in any way, this rule applies to you. This includes companies using U.S. correspondent banks, international payment processors, or outsourced compliance providers, too.
The implications go far beyond compliance. Payment structures, data retention policies, vendor agreements, and internal documentation systems must all adapt—immediately.
EU companies face an added risk.
Under GDPR and AML regulations, personal data collected for AML purposes generally must be deleted after five years unless there’s a specific legal obligation to keep it longer. That’s where the problem starts. OFAC has acknowledged this tension but won’t accept it as an excuse for non-compliance.
There is no transition period. No exemptions. No grace window.
Is your business ready?
Read my article: https://www.linkedin.com/pulse/ofac-trap-most-companies-fail-10-year-record-rule-now-soltesz-19a5f
Starting 21 March 2025, anyone subject to U.S. sanctions laws—including non-U.S. firms. If your business touches U.S. dollars, U.S. infrastructure, U.S.-owned entities, or sanctioned jurisdictions in any way, this rule applies to you. This includes companies using U.S. correspondent banks, international payment processors, or outsourced compliance providers, too.
The implications go far beyond compliance. Payment structures, data retention policies, vendor agreements, and internal documentation systems must all adapt—immediately.
EU companies face an added risk.
Under GDPR and AML regulations, personal data collected for AML purposes generally must be deleted after five years unless there’s a specific legal obligation to keep it longer. That’s where the problem starts. OFAC has acknowledged this tension but won’t accept it as an excuse for non-compliance.
There is no transition period. No exemptions. No grace window.
Is your business ready?
Read my article: https://www.linkedin.com/pulse/ofac-trap-most-companies-fail-10-year-record-rule-now-soltesz-19a5f
The OFAC Trap Most Companies Will Fail: The 10-Year Record Rule Is Now Law
OFAC’s new 10-year recordkeeping requirement is one of those silent regulatory changes that will quietly catch out hundreds of companies that simpl...
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More Updates From Viktoria
Viktoria S.
Apr 30, 2025
When a Citizenship Scheme Collides with Payment Reality
The EU Court just ruled Malta’s citizenship-for-investment scheme illegal, and we just have to wait and see if every client file tied to a Maltese setup now has to be re-checked again.
This change will definitely have an effect on how international clients structure their operations, how banks respond to nationality claims in the future, and how onboarding logic needs to be written going forward.
All banks and payment providers now have to be brought up to date, their risk profiles need to be reviewed, and the old thinking that allowed these clients through without proper checks must be replaced with a more serious and current approach.
What was once a fast track can now raise red flags. If your account, SEPA access, or license was built on this structure, you could be in trouble.
Read my article for more information: https://www.linkedin.com/pulse/when-citizenship-scheme-collides-payment-reality-viktoria-soltesz-pfu8e/
The EU Court just ruled Malta’s citizenship-for-investment scheme illegal, and we just have to wait and see if every client file tied to a Maltese setup now has to be re-checked again.
This change will definitely have an effect on how international clients structure their operations, how banks respond to nationality claims in the future, and how onboarding logic needs to be written going forward.
All banks and payment providers now have to be brought up to date, their risk profiles need to be reviewed, and the old thinking that allowed these clients through without proper checks must be replaced with a more serious and current approach.
What was once a fast track can now raise red flags. If your account, SEPA access, or license was built on this structure, you could be in trouble.
Read my article for more information: https://www.linkedin.com/pulse/when-citizenship-scheme-collides-payment-reality-viktoria-soltesz-pfu8e/
Viktoria S.
Apr 29, 2025
When the Lights Went Out: The Fragile Illusion of a Cashless Society
Yesterday Spain, Portugal and some parts of France was hit by a massive power cut. We had no phone lines, no internet, no payments, and no information. People panicked because they had no way to pay, no way to call for help, and no idea what was happening.
Our good old friend, cash, came back to save the day.
Supermarkets took advantage, raising prices and "forgetting" to declare and tax some extra income, while the whole idea of a cashless society was shown to be dangerously fragile.
The entire idea of a safe cashless society collapsed.
Read my article for more https://www.linkedin.com/pulse/when-lights-went-out-fragile-illusion-cashless-society-soltesz-d9pmf
Yesterday Spain, Portugal and some parts of France was hit by a massive power cut. We had no phone lines, no internet, no payments, and no information. People panicked because they had no way to pay, no way to call for help, and no idea what was happening.
Our good old friend, cash, came back to save the day.
Supermarkets took advantage, raising prices and "forgetting" to declare and tax some extra income, while the whole idea of a cashless society was shown to be dangerously fragile.
The entire idea of a safe cashless society collapsed.
Read my article for more https://www.linkedin.com/pulse/when-lights-went-out-fragile-illusion-cashless-society-soltesz-d9pmf
Viktoria S.
Apr 23, 2025
Why VCs Should Stop Wiring Money Upfront – And How Banks Can Win a Lot of New Business With This New Setup
Startups are sitting on investor money they do not need yet, which is not only risky but also costly. It is not only triggering banking red flags but also costing VCs millions in negative carry.
One freeze, one payment delay, or one compliance hurdle, and the entire business can collapse. However, in this setup, there is a huge opportunity for banks and PSPs to attract business with what everyone needs, and it is also very easy to implement.
The deferred funding model is not only better for both VCs and startups but also for the banks and payment providers. Founders and funds are not just looking for a place to park money but they want a trusted financial partner that is flexible, transparent, and responsive.
Whoever offers a real solution can win clients easily.
Read my article for more information: https://www.linkedin.com/pulse/why-vcs-should-stop-wiring-money-upfront-how-banks-can-soltesz-objqc
Startups are sitting on investor money they do not need yet, which is not only risky but also costly. It is not only triggering banking red flags but also costing VCs millions in negative carry.
One freeze, one payment delay, or one compliance hurdle, and the entire business can collapse. However, in this setup, there is a huge opportunity for banks and PSPs to attract business with what everyone needs, and it is also very easy to implement.
The deferred funding model is not only better for both VCs and startups but also for the banks and payment providers. Founders and funds are not just looking for a place to park money but they want a trusted financial partner that is flexible, transparent, and responsive.
Whoever offers a real solution can win clients easily.
Read my article for more information: https://www.linkedin.com/pulse/why-vcs-should-stop-wiring-money-upfront-how-banks-can-soltesz-objqc
Viktoria S.
Apr 21, 2025
The 2025 Banking Crisis: The Warning Signs Are Clear
Everyone still think that someone will step in before things collapse.
But the tools we used to delay the last crisis no longer work, and the safety nets around our funds are now quietly removed.
The recent move by the Bank of England to stop publishing bailout data is just one example of a broader change when we hide facts to pretend everything is OK.
But while asset prices are floating on empty promises and gold is rising because no one trusts the system anymore, the most damage will not come from the failure but from the delayed responses.
Read my article for more information: https://www.linkedin.com/pulse/2025-banking-crisis-warning-signs-clear-viktoria-soltesz-y3erf/
Everyone still think that someone will step in before things collapse.
But the tools we used to delay the last crisis no longer work, and the safety nets around our funds are now quietly removed.
The recent move by the Bank of England to stop publishing bailout data is just one example of a broader change when we hide facts to pretend everything is OK.
But while asset prices are floating on empty promises and gold is rising because no one trusts the system anymore, the most damage will not come from the failure but from the delayed responses.
Read my article for more information: https://www.linkedin.com/pulse/2025-banking-crisis-warning-signs-clear-viktoria-soltesz-y3erf/
