SOC 2 for Fintech

SOC 2 for fintech, bank-grade.

Fintech audits demand more than a Security-only report. Skadi scopes and delivers SOC 2 Type II with Processing Integrity, Confidentiality, and Availability — the criteria your sponsor bank and enterprise clients actually require. Every engagement is led by a senior CPA who has worked with ledger, payments, and lending platforms and knows where money movement risk actually lives.

4.9on Trustpilot
Independent SOC 2 Type II
Why this vertical is different

Audit challenges we solve for you.

Sponsor bank oversight

Partner banks run their own vendor reviews and expect SOC 2 evidence that matches their control matrix. A generic Security-only report reads as under-scoped and delays or blocks program approval.

Money-movement risk

Every code path that touches a ledger, transfer, or payout is high-risk. Controls must prove authorization, segregation of duties, completeness of processing, and end-to-end traceability from initiation to settlement.

Regulatory adjacency

SOC 2 sits alongside PCI DSS, state money-transmitter licenses, NYDFS Part 500, and future SOX obligations. Scoping must anticipate the full stack without duplicating evidence collection.

Reconciliation discipline

Daily recs are the fintech control — auditors, banks, and regulators all read them. Missing breaks, late resolution, or manual overrides without approval are the most common findings we see in fintech transitions.

Where auditors focus

Controls that matter most for your business.

Processing Integrity (PI1.1–PI1.5)

Completeness, validity, accuracy, timeliness, and authorization on every transaction path. Tested with end-to-end walkthroughs and detailed sampling — not accepted on a control-owner assertion.

Segregation of duties (CC5.3)

Engineers cannot unilaterally push money-moving code. Author ≠ approver ≠ deployer, enforced in the pipeline, evidenced from GitHub and deploy tooling with cross-referenced sampling.

Ledger & reconciliation controls (PI1.4)

Daily reconciliations against bank and processor statements, documented break investigation, aging thresholds, and evidence discrepancies are resolved within a stated SLA.

KYC / AML tooling (CC6.7, C1.1)

Access controls on customer PII and identity documents, monitoring on identity vendor calls, and evidence that flagged accounts follow the documented playbook (hold, SAR filing, closure).

Encryption & key management (CC6.7)

KMS/HSM usage for keys protecting financial data, dual-control rotation cadence, and separation of key custodians from data owners. Bank reviewers ask about this by name.

Change management on money paths (CC8.1)

Elevated approval requirements — including a second reviewer with financial-operations context — for any change to services that authorize or move funds. Evidenced end-to-end and sampled at higher rates than normal changes.

Third-party & sub-processor management (CC9.2)

Annual review of every sub-service organization's SOC report, tracking of complementary user entity controls, and evidence you actually operate the CUECs they list.

Fraud & transaction monitoring (CC7.2)

Rules coverage, alert triage SLAs, and evidence of investigation-to-resolution — increasingly asked for by both bank partners and regulated end customers.

Common Type II findings

What actually fails in this vertical.

Real deviations we see in SOC 2 Type II fieldwork — and what your platform and security teams should fix before the observation window starts.

Ledger reconciliation not evidenced daily

Recon runs but no signed artifact showing breaks investigated and resolved. Processing Integrity (PI1) exception writes itself if the recon output is not retained.

Evidence to collect
  • Daily recon report archive with sign-off per business day
  • Break-investigation ticket log with root cause + resolution
  • Recon runbook and control-owner assignment
  • Screenshot of variance thresholds and alerting rules
Money-movement approvals bypassable by engineers

Production DB access allows direct writes to the ledger. Segregate duties technically — engineers cannot approve their own transactions, ever.

Evidence to collect
  • Production DB access matrix showing no write on ledger tables
  • Change-management ticket for any break-glass DB write
  • SoD policy naming approver ≠ initiator
  • Approval-workflow config in the treasury/ops tool
Sponsor bank / partner obligations not tracked

BaaS/sponsor bank contract obligations (BSA/AML monitoring, reporting cadence) live only in a legal folder. Map to controls with owners and cadence.

Evidence to collect
  • Obligation register mapping each clause to a control + owner
  • Monthly/quarterly report archive sent to the sponsor bank
  • AML/BSA transaction-monitoring rule set and tuning log
  • Meeting minutes from sponsor-bank oversight cadence
Cardholder scope creep into non-PCI systems

PAN accidentally logged in application logs. Tokenize at ingress and prove non-CDE systems never see raw PAN — attestations from the auditor rely on it.

Evidence to collect
  • Tokenization architecture diagram + vendor attestation
  • Log-scrubbing rules for PAN + sample logs from the window
  • Data-flow diagram of the CDE
  • SAQ / AoC and quarterly ASV scan reports
KYC vendor evidence not retained

Vendor returns decisions but you keep only the pass/fail — auditors need the underlying evidence set for a sample of decisions during the window.

Evidence to collect
  • Sample KYC case files (ID doc, liveness, watchlist hit) for the window
  • Retention policy referencing regulatory requirements
  • Vendor contract + latest SOC 2 report
  • Escalation runbook for edge-case decisions
Cutover / release windows not aligned to settlement

Deploys during settlement windows caused reconciliation gaps. Change management must consider financial timing, not just uptime.

Evidence to collect
  • Deploy-freeze calendar overlaid on settlement windows
  • Release policy referencing freeze rules
  • Change-management ticket showing timing review sign-off
  • Post-deploy recon report for a sampled release

Why fintech SOC 2 is different

A generic SaaS can pass SOC 2 with Security only. A fintech usually cannot. Sponsor banks, card networks, and enterprise clients want proof that your ledger is complete and accurate (PI1), that customer financial data is protected (C1), and that your platform stays available under load (A1). Getting the scope right on day one saves a re-audit and — more importantly — the trust of your bank partner.

Bank sponsor readiness

Sponsor banks conduct their own vendor reviews and increasingly ask for SOC 2 reports as a baseline. We have seen fintechs delayed by 3–6 months because their initial report did not include Processing Integrity or did not reflect their actual money-movement architecture. Skadi scopes correctly on day one, and drafts your system description in a way that maps cleanly to the OCC-style questionnaires banks actually send.

Segregation of duties done properly

In fintech, SoD is not a policy statement — it is a technical control. Author, reviewer, and deployer must be distinct principals in the pipeline; ledger reads and writes must be separated from application engineers; and any manual override must generate an auditable ticket with independent approval. We test this by pulling live samples from your VCS, deploy system, and ledger — not by reading a policy PDF.

Pre-IPO and SOX-adjacent programs

For fintechs on an IPO track, SOC 2 controls become the foundation of future SOX 404 ITGCs. We design your program so the same evidence (change management, logical access, backups, monitoring) can be reused for SOX with minimal duplication — a significant cost saving in a future S-1 audit and less noise for your finance team when the external auditor arrives.

FAQ

Questions we hear from teams like yours.

Ready to scope your SOC 2 Type II?

Book a call and we'll walk you through timeline, scope, and pricing for your company.

Back to home