BaaS/API-first implementation plan

High-Level Implementation Plan: B2B

Financial Platform (BaaS/API-First
Approach)

1. Solution Overview
We will build a proprietary, web-based platform that acts as a unified dashboard and
orchestration layer, aggregating data and initiating actions across multiple regulated BaaS/API
providers. The platform will not hold client funds or operate its own payment rails; all financial
operations are delegated to licensed vendors via secure APIs. The system manages users,
workflows, and value-added features, while regulated partners handle compliance and
transactional execution.

2. Core Components & Flow

A. User Interface (Web App)

●​ Secure login for company owners, finance teams, and admins.

●​ Real-time dashboard: account balances, FX rates, payment status, supplier
management, insurance/factoring options.
●​ Initiation flows for onboarding, payments, FX, and more.
●​ Automated notifications, audit trails, and reporting.

B. Backend/API Integration Layer

●​ Central “orchestration” backend normalizes and abstracts vendor APIs (AISP, PISP,
KYC, FX, insurance, etc.).
●​ Handles all async events (webhooks, polling), manages state, retries, error handling,
and reconciliation.
●​ Implements RBAC (role-based access control) and business logic unique to the client’s
needs.
3. Key Functionalities & How They’re Built
A. Payment Integration (Supplier Payments & FX Transactions)

●​ API Connections: Integrate with one or more regulated BaaS vendors offering PISP
(Payment Initiation) and FX APIs (e.g., Railsr, Ebury, TrueLayer, Tink, Banking Circle).
●​ Payment Flow:
○​ User selects to “pay supplier” or “create FX deal” in the UI.
○​ System sends payment/FX initiation request to vendor via API.
○​ For large payments or cross-border, the system may allow selection of payment
rail (e.g., SEPA, SWIFT) if vendor supports.
○​ Track payment/FX status via webhook or polling from vendor.
○​ Display confirmation, failures, or required user actions in real-time.
●​ No Funds Custody: All payments are executed by the regulated vendor; your system
only initiates and tracks, never holds funds.

B. Automated Onboarding Process (Including Video Calls)

●​ KYC/KYB API Integration:

○​ Connect to vendors like Onfido, Jumio, or IDnow for onboarding and verification.
○​ The onboarding flow in your UI collects documents, ID scans, and schedules or
triggers a live video call (if required by vendor).
○​ System manages all required documents, status, and escalates edge cases to
compliance or support.
●​ Vendor manages compliance: All checks, approvals, and documentation storage are
handled by the vendor’s API, ensuring regulatory cover.

C. Payment Initiation Service Provider (PISP) Flow

●​ Initiation: User creates a payment order in your platform (e.g., “€32,000 to Supplier X”).
●​ Redirect & SCA: Your backend uses PISP vendor API to initiate payment. User is
securely redirected to their online banking (via Open Banking) for Strong Customer
Authentication (SCA).
●​ Approval: User authenticates with their bank, confirms the payment; the bank notifies
the vendor of success/failure.
●​ Confirmation: Vendor notifies your backend (webhook/API callback); system updates UI
and logs the transaction.
●​ FX/International: If cross-border, the platform can route funds via vendor-supported FX
or SWIFT rails.
D. Account Information Service Provider (AISP) Flow

●​ Bank Connections:
○​ User links one or more business bank accounts via secure OAuth/Open Banking
flow.
○​ Vendor (AISP) retrieves account data: balances, transaction history, account
details.
○​ Data is normalized and displayed in real-time dashboard.
●​ Unified View:
○​ Show consolidated balances, per-bank transactions, payment history, and
supplier activity.
○​ All account data is refreshed via webhook or scheduled polling from AISP
vendor(s).

E. Insurance & Factoring

●​ API Integration:
○​ If vendors support insurance/factoring products, expose options in the UI and
allow users to initiate quotes/applications via API.
○​ All underwriting, compliance, and documentation handled by vendor partners.

4. Compliance & Security

●​ No Regulatory License Needed: All regulated activities (payment initiation, account
info, FX, insurance) occur via vendors holding the appropriate licenses.
●​ GDPR Compliance: All user and transaction data is encrypted, access-controlled, and
logged. DPAs are signed with every vendor. Audit logs are maintained.
●​ Audit & Monitoring: All actions, access, and API calls are fully auditable; monitoring
and alerts for system/vendor errors.
5. Technical Architecture (Simplified)

[Frontend Web App]

|
V
[Backend Orchestration Layer]
|
|---> [AISP Vendor API (Bank Data)]
|---> [PISP Vendor API (Payments)]
|---> [FX Vendor API]
|---> [KYC/KYB Vendor API]
|---> [Insurance/Factoring API (if available)]
|
[Database] [Audit Logs] [Monitoring]

●​ Abstraction Layer: Shields frontend from vendor quirks, supports hot-swapping

vendors if needed.
●​ State Management: Handles all async flows (webhooks, polling, status updates).
●​ Security: Role-based access, secure credential management, logging.

6. Implementation Steps
1.​ Scoping & Vendor Selection:
○​ Finalize feature set, shortlist and vet regulated vendors for each core function.
2.​ System Design & Architecture:
○​ Design data models, API abstractions, security policies, and workflows.
3.​ Environment Setup:
○​ Provision cloud infrastructure, set up CI/CD, monitoring, secrets management.
4.​ Core Development:
○​ Build backend integration/adapters, frontend UI, business logic, and user flows.
5.​ Testing & Compliance:
○​ Implement automated and manual tests; validate all compliance, security, and
audit requirements.
6.​ User Training & Go-Live:
○​ Onboard internal users, conduct training, monitor platform in production.
7.​ Ongoing Maintenance:
○​ Monitor vendor status, handle upgrades, maintain compliance, support users.
7. What You Control vs. What the Vendor Controls
Area Your Platform Vendor(s)

UX/UI Fully custom N/A

Workflow Fully custom N/A

API Integrations All calls, data normalization Core financial/data services

Funds Handling Never handled Fully handled

KYC/KYB Workflow & document Verification, storage, legal

collection

Payments/FX Initiation & tracking Execution, settlement, legal

Compliance Data handling, audit, DPA, Regulated activities, licenses

GDPR

Audit/Logging Full internal, across system Own logs for regulatory use

8. Production Compliance Checklist

●​ Contracts with all vendors (financial, KYC, insurance, etc.).
●​ DPAs in place and data maps maintained.
●​ GDPR policies for internal users.
●​ Encrypted, access-controlled data storage.
●​ End-to-end audit logging.
●​ Monitoring, alerting, and incident response protocols.

9. Summary
●​ You build the interface, workflows, logic, and user experience.
●​ All financial transactions and compliance are routed via regulated, API-driven partners.
●​ No direct fund handling, no in-house licenses required (unless you expand beyond
vendor APIs).
●​ All compliance, data protection, and audit requirements remain mandatory even for
internal use.