State of Financial Crime 2023 Report

ComplyLaunch Partner Interview: Daniel Marsh, Head of Customer for Seccl

Corporate Knowledge & Training

Anti-money laundering (AML) and combating financing terrorism (CFT) compliance is complicated and not always well understood. Still, businesses must learn to navigate the regulatory landscape from the start. Otherwise, they leave themselves open to exploitation by opportunistic criminals and, ultimately, regulatory action.

But not all businesses have the resources and expertise to protect themselves. Early-stage startups, in particular, are vulnerable to overlooking the nuances of compliance requirements.

To address this issue, ComplyAdvantage launched its ComplyLaunch™ program. The goal: to provide qualified startups with free access to the tools and resources they need to manage AML/CFT risks and compliance requirements. 

The response has been tremendous with the first cohort of startups having signed up in just a few days. The program has also garnered the support of world-class organizations, including Seccl, a technology platform providing custody for financial services firms looking to safeguard their clients’ assets. ComplyAdvantage recently sat down with Dan Marsh, the Head of Customer at Seccl, to discuss why AML/CFT compliance is vital and how ComplyAdvantage’s new program can help.


Let’s start with a bit of context. Please tell us what Seccl is and what high-level market opportunity your company is innovating for.

Seccl is a platform technology business. We provide investment services to companies across the UK who want to make financial markets accessible for their customers. We spent the last five years building the infrastructure that sits behind global financial markets to allow easy plug-and-play access for retail consumers to trade, invest and save for their futures.

A program like this is powerful for startups because it will protect the business before they know they need to be protected.

Daniel Marsh, Head of Customer, Seccl


Who are your customers? What solutions have you developed to help your customers innovate or grow their businesses?

Our customers typically fall into two camps. We serve professional financial services providers — referred to in the UK as wealth managers or financial advisors. Those individuals build deep, long-lasting relationships with individuals and couples across the UK, helping them navigate the complexities of financial life.

They might offer recommendations as to what individuals should do with their money, such as opening specific tax products or investing in a certain way to meet specific goals, whether that be sending a grandchild to school, helping kids get through university, helping someone get their foot on the property ladder or, probably the most common, helping to provide for a comfortable retirement.

The other customers we serve are at the other end of the spectrum. We serve businesses that want to embrace the force multiplier of technology to democratize access to financial markets. Typically, we would view these as wealthtech or fintech businesses, and the principal problem they’re trying to solve is that markets have traditionally had a relatively high barrier to entry. You’ve got to have a certain amount of wealth to make it worth it. You’ve got to have a certain amount of cash to invest; otherwise, the fees and so on will work against you.

Our biggest innovation, I think, was consolidating those two markets and realizing that both are served by a highly efficient digital experience, one where there is a high level of security for the underlying assets and transparency around what is happening in the platform. Most crucially, we offer a series of open APIs to allow users to connect and work from within their own domains. Instead of building a separate app that you have to log in to, which is super clunky, you can drive the activity straight from the experience that your customers already know and love.


That is brilliant. Is your company one that could be directly or indirectly impacted by money laundering and related financial crimes? If so, could you tell us why?

Yes, very seriously. At the end of the day, we receive money from clients. So when we look at financial crime, we look at several areas. 

First, we need to make sure the individuals that use our customers’ services and place their money with us are people we want to do business with. That is, we need to make sure they are who they say they are and that they’re not someone who has perhaps committed crimes of a certain nature abroad and who we don’t want exposure to from a business risk perspective.

Second, we look at how people use our system. Our system, as a custody and trading system, works with clients’ money. When you look at crimes from a money laundering perspective, the activities we watch for include placement and layering. Although the activity may occur outside our system, the impact is felt within our system.

So it’s critical that every firm we work with, firstly, has a rigorous process in place. Secondly, it’s important to have a deep bond of trust between both businesses because, ultimately, the only way you can protect yourself is to align yourself with partners who think like you do. As long as you’re both consumed by making sure that you’re doing the right thing by your customers while keeping them and yourself safe, you’ve got a really strong platform for growth for both businesses.


What motivated your team to join the ComplyLaunch program?

There’s the obvious: the value it brings to our customers. But that’s not, in my opinion, where it starts. When you want to build a partnership with any organization, what you’re looking at is: do we think the same way?

ComplyAdvantage’s focus, in my experience, has always been on enabling entrepreneurs to be successful. By nature, every one of our customers is entrepreneurial, so the fit probably couldn’t be better. On top of that, the program is clearly very compelling for firms in that it helps get them over some of the fixed costs that can sometimes act as a barrier.


Why do you think it’s important for startups to have free access to programs like ComplyLaunch?

If we look at it as a society, the idea that barriers to entry stifle innovation is a broad-brush answer. The more access that can occur at lower fixed initial costs — for example, the free program you’re launching — the greater the number of people who can bring new ideas to the market. Those new ideas will generate innovation, and those innovations will generate societal and customer benefits.

In terms of the firms themselves, it’s really important because when you’re working for a new startup, you’re making a choice, and that choice is always: what do I do with this pound that I’ve got here? You will do or die by a few key parts.

Protecting your business is critical, but it’s also easy to under-invest in it because it’s not sexy. It won’t help you with your growth metrics when you go and sit in front of that VC. It won’t help you socially sell to your friends. It is often something that doesn’t get thought about until the business is quite successful and in quite a lot of trouble.

A program like this is powerful for startups because it will protect the business before they know they need to be protected.


What advice would you give founders who are thinking about building a new fintech or financial service offering?

First, to be bold. There’s so much innovation in the markets that if you follow the trajectory everyone else follows, you’ll get the same outcome, and your ability to innovate will be marginal — maybe you’ll see a 10% or 20% improvement. Boldness in terms of what you’re prepared to change will have a force multiplier effect for you immediately but also over time.

Second, and this goes back to something we talked about before, it’s about trust. You want to work with a partner that thinks like you do because it’s very, very hard as a startup founder, or for any business unless you’re very mature, to anticipate all 10 of the 10 issues that will come your way.

You’ll probably only know about two of them. If the other partner doesn’t think like you, when the other eight come up, it’s going to be your problem. So you’re looking for someone who makes those eight problems a shared problem, because a problem shared is a problem halved; then a problem halved, that’s a problem solved. Ultimately, those partnerships and the trust that you build are probably more important than almost any other ingredient that you can pour into your startup early on.


Any last thoughts that you want to share?

We get very excited here at Seccl when we hear about programs such as this one because it’s very, very rare in the market to offer something with no strings attached. It almost always comes with a catch and then a follow-on. But what is interesting here is that this is about driving innovation. It’s about increasing access to financial markets, which, for our customers, is incredibly important. So this isn’t one of those opportunities you want to spend the next three months working out whether or not you want to do it. If you think there’s a fit, just get stuck in.

This interview has been edited and condensed. Learn more about the ComplyLaunch™ program and how you can get involved by clicking here.

Originally published May 11, 2021, updated October 19, 2022

Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.

Copyright © 2023 IVXS UK Limited (trading as ComplyAdvantage).