Company Context

Airwallex Pty is a global payments and financial platform serving SMBs and mid-market businesses across APAC, Europe, and North America. Its core products include Global Accounts, Transfers, Cards, and Spend. Airwallex is planning to expand onboarding and transaction coverage into 8 additional markets over the next 12 months, but its current sanctions and politically exposed persons (PEP) screening stack is becoming a bottleneck for both product velocity and compliance operations.

Strategic Situation

You are the Engineering Manager responsible for a platform decision: should Airwallex build a sanctions/PEP screening capability in-house as part of its risk and compliance infrastructure, or integrate a third-party vendor and focus internal engineering effort elsewhere? The decision matters now because onboarding volume is rising, regulators are increasing expectations for explainability and auditability, and commercial teams want faster market launches. The choice will affect cost, launch speed, control over roadmap, and long-term defensibility.

Data Points

Additional context:

• A vendor claims it can reduce false positives by 35% versus Airwallex's current setup.
• Internal risk engineering believes an in-house system could reduce false positives by 50% after 12 months, but only 15% in the first 6 months.
• Delaying market launch by 1 quarter is estimated to defer A$6M in gross profit.
• Engineering capacity available: 10 engineers and 2 data scientists, but those same teams are also needed for Airwallex Issuing and Global Accounts roadmap commitments.

Deliverables

1. Assess whether Airwallex should build, buy, or pursue a hybrid approach for sanctions/PEP screening.
2. Quantify the major trade-offs across cost, speed, compliance risk, and strategic control.
3. Evaluate how the decision changes over a 12-24 month horizon rather than only at launch.
4. Recommend a go-forward strategy and decision criteria for revisiting it later.
5. Outline the implications for engineering resourcing and market expansion.

Constraints

• Airwallex must support launches in 8 new markets within 6 months.
• Compliance and audit requirements cannot be weakened during the transition.
• Budget for the initiative is capped at A$5M in year 1.
• Leadership is unwilling to materially delay Airwallex Issuing and Global Accounts roadmap milestones.