You are the program manager for MercuryPay, a mid-market fintech that provides multi-currency wallets and payouts for e-commerce platforms and gig-economy marketplaces. MercuryPay processes $9B/year in payment volume and holds customer funds in pooled accounts across 12 markets (US, Canada, UK, Ireland, Germany, France, Spain, Netherlands, Singapore, Australia, Mexico, Brazil). The company is preparing to launch a new product line: “Instant Payouts” for marketplaces, which requires tighter treasury operations because funds move faster and liquidity buffers are smaller.
A recent internal audit found that treasury-related documents (e.g., bank account opening packets, KYC/KYB attestations, board resolutions, signatory lists, beneficial ownership forms, sanctions screening evidence, and monthly bank reconciliation sign-offs) are managed through a mix of email threads, shared drives, and ad-hoc spreadsheets. This has caused missed renewal deadlines, inconsistent approvals, and incomplete audit trails. In one market (Brazil), a missing signatory update triggered a bank freeze that delayed payouts for 18 hours, impacting ~42,000 end users and creating a contractual SLA breach with a top marketplace customer.
The CFO and General Counsel have mandated that before Instant Payouts can expand beyond the US and UK, MercuryPay must implement a standardized, compliant, and time-bound treasury document workflow with clear ownership, automated reminders, and evidence retention. You have 10 weeks to deliver a solution that can withstand a regulator or banking partner audit and reduce operational risk without slowing growth.
| Constraint | Details |
|---|---|
| Timeline | 10 weeks to reach “audit-ready” for 12 markets; Instant Payouts expansion decision at Week 11 exec review |
| Team | 3 backend engineers, 1 workflow/front-end engineer, 1 QA, 0.5 data engineer, 1 compliance analyst, Treasury Ops (2 people); no new headcount approved |
| Budget | $120K for tooling/vendors (e.g., e-sign, document management, archival storage, external counsel review) |
| Regulatory/Partner Requirements | Evidence retention 7 years in some markets; certain banks require wet signatures or notarization; renewal cycles vary (annual, semi-annual, event-driven) |
| Security | Documents contain PII (beneficial owners, IDs). Must meet internal security baseline: encryption at rest, access logging, least privilege, SOC2 controls |
| Dependencies | Banking partners in Germany and Brazil require updated signatory lists within 5 business days of changes; Legal review SLA is currently 10 business days |
Your answer should demonstrate how you ensure compliance while still executing on time: how you prioritize, drive alignment, manage dependencies, and keep the program on track under constraints.