1. Start with licence boundaries
Record the licensee, authorised activity, territory, domains, acquisition channels and each contractor’s role. A white-label arrangement does not replace a licence or automatically extend its scope.
2. Translate rules into controls
Build a matrix: requirement → process → system control → owner → evidence. Cover onboarding, age checks, KYC, restrictions, transaction monitoring and incident management.
3. Design reporting before launch
In August 2026 the Kyrgyz financial regulator published separate rules on state supervision, licensing, reporting and disclosure. Data models and audit logs should therefore be agreed before providers are connected, not after release.
Official source