‍Banking regulators require payment service providers to implement comprehensive compliance measures to prevent financial crime and money laundering, and to maintain consumer trust in the financial system. However, true compliance goes beyond mere regulation: it requires a culture of integrity that is self-regulating. This is how Unzer has successfully managed this transformation – and why leadership plays a key role in the process.  

In recent years, the Federal Financial Supervisory Authority (BaFin) has been paying closer attention to the entire payments sector. This scrutiny is both necessary and appropriate, as tackling financial crime and money laundering calls for rigorous oversight. At the same time, increased regulation compels financial institutions to establish stable, transparent, and trustworthy business processes.

Companies such as Unzer have invested significantly in recent years to enhance their compliance frameworks. We have introduced a group-wide compliance strategy, realigned our risk management approach, optimised internal processes, strengthened control mechanisms, and established structured monitoring. In addition, we have overhauled our customer onboarding process with clear criteria and implemented software that continuously monitors merchants and transactions.

As a result, we can justifiably claim today that our compliance and governance systems meet the highest industry standards. The lifting of BaFin’s special mandate and the onboarding ban further demonstrates the progress we have made over the past years.

A Culture of Integrity as a Key to Success

Structures, software, and processes are but one aspect of compliance. For me, as the responsible Compliance Officer, something else is paramount: the need for a long-term culture of integrity that is intrinsically self-regulating and adheres to rules by conviction. It requires an inner attitude among all staff members that actively counters possible misconduct from within. This is precisely the crucial advance we have made.

Let me explain. The values and convictions of a company are the foundation for sustainable cultural change. Integrity comes first and foremost, as without it, a company cannot meet the legitimate expectations of its stakeholders. Trust is created only when all parties consistently act according to the highest ethical standards – in word and deed.

Rules Alone Are Not Enough

The compliance guidelines from the EU Commission and national regulators run to thousands of pages. They are important, but cannot cover every eventuality. In many cases, rules are clear, decisions straightforward. Yet, it is often integrity that must guide the actions of management boards, executives, and employees. Simply put, staff should not only do what is legally permissible, but also what is right.

That is why we support and train our staff to make decisions based on integrity. Direct communication between the Compliance Department and the wider organisation is central to this endeavour. Policies, training, monitoring, and quality checks serve as a compass in the complex landscape of compliance.

At the same time, every employee shares responsibility. Integrity means questioning things and actively participating. We must foster an environment in which criticism is not only permitted, but actively encouraged. Our staff should feel empowered to openly raise concerns. Only through candid communication and constructive criticism at all levels of the hierarchy can genuine cultural change occur.

This is precisely what we have implemented at Unzer. Our corporate culture is founded on integrity and transparency. We have established a whistleblower hotline and conduct regular training sessions to embed compliance as an integral part of our corporate ethos. In addition, we promote a speak-up culture, where all voices are heard – not just the loudest or most dominant. Our Code of Conduct sets out clear principles for ethical and responsible behaviour and encourages employees to raise concerns openly.

Responsibility Starts at the Top

A culture of integrity must be exemplified by leadership; thus, compliance starts at the top. Managers must recognise their responsibility for ethical business conduct, lead by example, and take their monitoring duties seriously. Role models set the standard. Ultimately, no internal or external regulation, however sound, can replace good, responsible management.

Integrity is not established solely by rules and systems, but by people who embody these values in their daily actions. At Unzer, we are firmly committed to continuing on this path.