WorkDWG AC-102
Leading a real-estate crowdfunding platform through its EU licence audit, as COO
Three years as COO of a regulated real-estate crowdfunding platform. Adrian was the lead on the authorisation and audit with the ASF, built automated KYC and AML onboarding and the investor-protection flows, and the platform received its EU crowdfunding (ECSP) licence in March 2024.
Mar 2024ECSP licence granted by the ASF
- Company
- HighCrowd, real-estate crowdfunding platform for retail investors
- Role
- Chief Operations Officer. Lead on the authorisation process with the ASF, Romania's financial regulator, and owner of the operations behind it.
- Timeline
- October 2022 to October 2025. Licence granted March 2024.
- Status
- Licensed ECSP operator
Context and the problem
HighCrowd lets retail investors fund real-estate projects in a regulated market. When Adrian joined as COO, it had a product and no licence. Under the EU crowdfunding regulation (ECSP), the platform needed an authorisation from the national regulator, and that authorisation ran through operations: the processes, the controls and the evidence behind them.
What was broken
A platform with a product and no licence, in a regulated market. Under the EU crowdfunding regulation the authorisation ran through operations: the processes, the controls and the evidence behind them all had to be ready for the regulator to audit. Onboarding an investor took about 45 minutes (internal measure).
What it cost
- No licence meant no regulated product to offer retail investors.
- About 45 minutes of onboarding work per investor before the KYC and AML automation (internal measure).
- Every policy without a working process behind it was a gap the regulator could find in the audit.
The brief
Turn a start-up into a licensed operator while the business kept running: produce the authorisation file the regulator examines, pass its audit, and run investor onboarding and fund flows that hold up under inspection.
Constraints and stakes
- The regulator examines evidence, not intentions: every policy needed a working process behind it.
- Retail investors, so the ECSP investor-protection rules apply to every account, from the entry test to the reflection period.
- Investor money moves only through segregated flows at a licensed payment partner, under PSD2.
- A distributed team, with product, engineering, legal counsel, the payment partner and technology providers all on the critical path.
What was at stake
Retail investors' money and a national regulator's audit. A policy that existed only on paper, or an investor check that could not be shown on request, would hold up the licence and the business with it.
Adrian's role and team
- Chief Operations Officer for three years, and the lead on the authorisation process and audit with the ASF.
- Led and mentored a cross-functional, distributed team.
- Coordinated product, engineering, legal counsel, the payment partner and technology providers through the authorisation.
- Set the KPIs and operating cadence the company ran on.
The approach, from 0 to 100
Oct 2022
Joined as COO: a platform with a product and no licence, in a regulated market.
Authorisation file
Penetration testing, the architecture review and the policy set the regulator examines: risk, complaints handling, conflicts of interest, business continuity and outsourcing.
Onboarding
KYC and AML onboarding automated on LemonWay under PSD2: identity checks, bank linking and segregated fund flows, from about 45 to 8 minutes per investor.
Investor protection
The flows ECSP requires on every retail account: an entry knowledge test, a loss-bearing simulation, key investment information sheets and the reflection period.
Operations
Approval flows, exception handling, investor support and regulatory reporting, run on the KPIs and cadence Adrian set.
25 Mar 2024
ASF decision: the ECSP licence is granted. Romania's fourth, and the second for real estate.
Oct 2025
Three years as COO, with seven-figure investor funding placed through the platform during that tenure and every investor check ready for inspection.
What was built
- The ASF authorisation file and audit. Penetration testing, the architecture review and the policy set the regulator examines: risk, complaints handling, conflicts of interest, business continuity and outsourcing.
- Automated KYC and AML onboarding on LemonWay under PSD2: identity checks, bank linking and segregated fund flows, cutting onboarding from about 45 to 8 minutes per investor (internal measure).
- The investor-protection flows ECSP requires: an entry knowledge test, a loss-bearing simulation, key investment information sheets and the reflection period.
- The operating system behind a regulated product: approval flows, exception handling, investor support and regulatory reporting, with the KPIs and operating cadence the company ran on.
How the system fits together
DWG AC-102System drawingRev Oct 2026
- Outside the system: a person, a ledger, a regulator
- Built by Adrian
- Human approval or a hard check
- Result
- Boundary
Data path
- 01Investor registers
- 02Identity and AML checks at the payment partner
- 03Entry knowledge test and loss-bearing simulation
- 04Key investment information sheet and reflection period
- 05Investment through segregated fund flows
Safeguards and controls
- Penetration testing and an architecture review with the regulator before authorisation.
- Investor money moved only through segregated flows at a licensed payment partner, under PSD2.
- ECSP investor protection on every retail account: entry knowledge test, loss-bearing simulation, key investment information sheet and reflection period.
- Every investor check documented and kept ready for inspection.
How it was tested
Every investor check was documented and kept ready for inspection. The policy set was written to match how the platform actually ran, so the audit tested real processes rather than paperwork. Regulators ask for evidence, not intentions, and the AI systems Adrian builds today carry the same habits: written controls, audit trails, human sign-off and documentation that survives an inspection.
Results
- Mar 2024EU crowdfunding (ECSP) licence granted by the ASF: Romania's fourth, and only the second for real estate
- 45 to 8minutes per investor to onboard, after the KYC and AML automation (internal measure)
- 3 yearsas COO, with seven-figure investor funding placed through the platform during that tenure
| Measure | Before | After |
|---|---|---|
| Licence | None: a product without authorisation | ECSP licence, March 2024 |
| Onboarding per investor (internal measure) | about 45 minutes | about 8 minutes |
What the platform kept
- An EU crowdfunding (ECSP) licence, granted by the ASF in March 2024.
- A policy set written to match how the platform actually ran: risk, complaints handling, conflicts of interest, business continuity and outsourcing.
- Investor onboarding automated at a licensed payment partner, with every investor check documented and ready for inspection.
- An operating system for a regulated product: approval flows, exception handling, investor support and regulatory reporting.
Stack
- ECSP, Regulation (EU) 2020/1503
- LemonWay (PSD2)
- KYC and AML
- Penetration testing
- Policy set and regulatory reporting
Similar problem?
Describe the process, the systems and the constraint. Hiring for this skill set? The CV has the full record.