Project Context

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.

Stakeholder Landscape

• CFO (Executive Sponsor): Wants reduced operational risk and predictable close processes. Pushes for a solution that scales to new markets without adding headcount.
• General Counsel / Compliance: Prioritizes auditability and “no gaps” in evidence retention. Will block expansion if controls are weak.
• Treasury Operations Lead: Owns day-to-day document collection and renewals. Wants a workflow that reduces manual chasing and clarifies who signs what.
• Instant Payouts Product GM: Competing priority—wants to launch 6 additional markets this quarter to hit revenue targets. Concerned that compliance work will slow roadmap.
• Engineering Manager (Internal Tools): Has limited capacity and is already committed to a finance data warehouse migration; can offer only partial bandwidth.

Constraints

What You Need to Deliver (Candidate Tasks)

1. Execution plan and roadmap: Propose a 10-week plan with phases, milestones, and explicit trade-offs (what you will and will not do).
2. Compliance-by-design workflow: Define how you will ensure each document is complete, approved by the right parties, stored correctly, and retrievable for audit.
3. Operating model: Clarify RACI across Treasury Ops, Compliance/Legal, Finance, and Engineering. Include escalation paths for overdue items.
4. Launch and rollout plan: Decide whether to launch all 12 markets at once or phase by risk/impact. Include a rollback/containment plan.
5. Success metrics and monitoring: Define measurable outcomes (timeliness, completeness, audit readiness) and how you’ll instrument/report them.

Complications (Realistic Curveballs)

1. Week 3: The Internal Tools EM informs you that one backend engineer is pulled into a P0 incident stream for 2 weeks (capacity drops ~25%).
2. Week 5: Legal flags that Brazil now requires an additional beneficial ownership declaration for certain entity structures, increasing document scope for that market.
3. Week 7: A top marketplace customer demands proof of controls after the prior bank freeze incident and asks for an attestation within 14 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.