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REAL CLIENT CASE STUDY · CASE 47

Embedded Finance Activity-Gap Analysis

Fintech / legalising an operating model

Financial & Regulated
EXPLANATORY DIAGRAM · CASE 47
01Actual customer journey
→
02existing licence coverage
→
03activity gap
→
04remediation
Existing tech activity6202-005
Gap activityFinancing Broker 6619-018
Business modelBorrower ↔ platform ↔ lender
Investigation goalLegalise full operation
CLIENT REQUIREMENT

An existing technology group wanted to enable SMEs and vehicle buyers to identify loan options through a platform connecting POS acquirers, dealerships and lending institutions.

CHALLENGE

The existing IT Network Services activity covered the technical-service layer but did not clearly cover acting as a facilitator between borrowers and lenders. The operational model therefore contained a licensing gap.

SOLUTION

The investigation kept Information Technology Network Services 6202-005 for the software/technical component and identified Financing Broker 6619-018 as the additional activity needed to cover the loan-facilitation component, with the source proposing addition under the existing DIFC licence.

WHY VANTABLACK

This is the type of investigation that matters after incorporation: compare what the business is really doing today against what its licences actually cover, then close the gap before growth increases exposure.

CASE LOGICActual customer journey → existing licence coverage → activity gap → remediation.

Source investigation dated March 2025. The report's conclusion on DIFC activity addition/external approvals must be revalidated against the current DIFC/DFSA regulatory perimeter before implementation.

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