The partner may offer a workable route into the market. But the documents in this example leave two important questions unanswered: whether its permissions cover your proposed service, and who is responsible when a payment raises a concern. I would resolve both before committing to a launch date.
The proposed model
Your company would provide the app and bring in customers. A local partner would receive and settle payments in one African market. You plan to rely on that partner’s permissions.
The findings and what is still missing
What the documents tell us
The sample file contains a product outline, a licence copy supplied by the partner and a draft agreement. The draft gives the partner responsibility for settlement, but says only that it will “handle compliance”.
What they do not establish
The licence copy alone does not establish that this particular arrangement is covered. The file also leaves open who contracts with customers and who owns customer checks, sanctions alerts, monitoring and reporting.
Where you depend on the partner
You would rely on its permissions, settlement service and access to transaction records. The agreement needs to make clear what information your team can obtain and who can stop a payment while a concern is investigated.
The next three actions
- Confirm the permitted route. Obtain current permission evidence and ask qualified local counsel to assess the proposed arrangement, including whether your company needs its own authorisation.
- Agree who does what. Set out who owns each customer and financial-crime task, what information is shared and how concerns are escalated.
- Walk through a difficult payment. Test who spots the issue, who can hold the payment and who makes and records the decision.
When to reconsider: Review the recommendation once the permission questions are resolved and the responsibilities are agreed and tested. If the proposed model cannot be supported, change the route or pause the launch.
A full diagnostic would include the agreed scope, source references, evidence dates, assumptions and limits. This extract shows the management summary only.
