In this episode of Wrestling Payments, host Elyssa Morgan sits down with Sanjiv Sanghvi and Stephen Coburn from Avalo Holdings. Together, they explore how financial institutions can shift compliance from a cost center to a source of growth by embracing a Know Your Customer’s Customer (KYCC) approach. Sanjiv and Stephen explain why moving from institution-level trust to transaction-level verification helps banks and credit unions unlock new fee income and low-cost deposits—without needing to overhaul their core systems. 

Sanjiv highlights the blind spots in the traditional model, where banks rely on their clients’ compliance controls instead of verifying each transaction’s parties and purpose. By digging into the details of each transaction and sharing information across institutions, banks can reduce false positives, lower compliance costs, and build stronger defenses against risk. Stephen adds that new technology enables these changes without massive capital investment. Tools now exist to help even small banks efficiently serve fintech and correspondent banking partners. 

For leaders facing squeezed margins and rising costs, Sanjiv and Stephen offer a clear message: meaningful growth requires a deliberate strategy, cross-team buy-in, and the right technology. They urge institutions to define their goals, work closely with compliance teams, and build new lines of business that can scale. When compliance becomes a competitive edge, banks can create lasting value for both their customers and their bottom line. 

Guest-at-a-glance 

💡 Name: Sanjiv Sanghvi
💡 What they do: Board Member
💡 Company: Avalo Holdings
💡 Noteworthy: Sanjiv brings decades of banking experience and specializes in helping financial institutions turn compliance and payment operations into business growth opportunities.
💡 Where to find him: https://www.linkedin.com/in/sanjiv-sanghvi 

💡 Name: Stephen Coburn
💡 What they do: Founder and CEO
💡 Company: Avalo Holdings
💡 Noteworthy: Stephen leads technology and solutions for banks, focusing on enabling fintech and correspondent banking partnerships through practical compliance and risk management tools.
💡 Where to find him: https://www.linkedin.com/in/stephencoburn/ 

Key Insights 

Compliance Can Drive Growth, Not Just Cost
Many financial institutions still see compliance as a burden—something that drains resources and slows business. This view is outdated. By shifting from institution-level trust to transaction-level verification, banks and credit unions can turn compliance into a business driver. Using Know Your Customer’s Customer (KYCC) methods, teams can see beyond their immediate clients and assess risk at the transaction level. This approach opens doors to new business lines, such as fintech and correspondent banking partnerships, which can bring in low-cost deposits and fee income. When compliance becomes an active part of growth strategy, it helps organizations build trust, reduce risk, and compete for new opportunities without overhauling their core systems. In today’s market, turning compliance into a revenue engine is not just possible—it’s essential. 

Transaction-Level Data Cuts Risk and False Positives
Legacy compliance tools often create more problems than they solve. High false positive rates and alert fatigue waste time and tie up staff. The root cause is a lack of context—systems only see basic information, like names and addresses, rather than the full picture of each transaction. When banks and fintechs share detailed data about the parties and purposes behind each payment, risk teams can spot real threats and let legitimate business move faster. Transaction-level data supports better due diligence, reduces compliance costs, and strengthens defenses against fraud and money laundering. By moving past surface checks and relying on richer information, financial institutions can focus on real risks and stop wasting resources on cluttered alerts. 

Growth Requires Focus, Buy-In, and the Right Tech
Chasing too many new ideas at once leads to scattered results and missed targets. For compliance-driven business lines to make a real impact, banks need a clear strategy and the right people involved from day one. That means setting specific growth goals, involving compliance and risk teams early, and building a business case everyone can support. Technology no longer needs to be a barrier—modern platforms can run alongside core banking systems and connect through simple APIs, rather than requiring an expensive overhaul. When institutions focus on a meaningful market, invest in the right tools, and commit to scaling what works, compliance-driven growth becomes achievable. Success follows when leaders align on purpose, plan for scale, and use technology to make smarter, safer decisions. 

Episode Highlights 

Flipping the Compliance Script: From Cost to Revenue 

00:00:44 – 00:01:41[Text Wrapping Break]The episode opens with a direct challenge to the old view of compliance as a back-office burden. The discussion reframes compliance as a potential revenue driver for banks, credit unions, and fintechs. By shifting from institution-level trust to transaction-level verification—through Know Your Customer’s Customer (KYCC) practices—organizations can create new growth opportunities. This approach not only builds stronger compliance programs but also unlocks new deposit and fee income streams, even allowing for deposit growth without added cost. The message is clear: institutions that treat compliance as only a cost are missing out on significant business value. 

"Today we're flipping the compliance conversation on its head. So, whether you're a $500 million community financial institution or a global institution, the challenge is the same. How do you turn compliance from a cost center

In the debut episode of Payments on Tap, host Elyssa Morgan sits down with Kevin Johnston, Chief Banking Officer at Braid Technologies, to unpack what it really takes for community banks and credit unions to build defensible, scalable FinTech partnerships. Kevin draws on his firsthand experience as former COO of Portage Bank in Seattle — a tiny $11 million charter he and four partners acquired out of Minnesota and grew into a high-performing institution with an active FinTech integration program. The conversation is grounded in data from NEACH's 2025 FinTech Collaboration Survey, which revealed a stark gap: 72% of financial institutions see FinTech partnerships as critical to growth, but only 28% feel prepared to execute them.

Kevin walks through the hard lessons learned from his early, admittedly naive foray into hosting wallets for a social media company — including the moment he realized the partner could change KYC thresholds without the bank's knowledge. That experience became the catalyst for what Braid Technologies builds today: software infrastructure that puts the bank in control of rules, compliance triggers, and transaction monitoring rather than relying on intermediary layers or legal agreements as the primary safeguard. The conversation covers everything from BSA backlogs and OFAC clearing to why middle managers should see FinTech integration as a career-building opportunity, not a burden.

Elyssa and Kevin also preview the FinTech Integration Leadership Series launching this spring — a cohort-based executive program co-developed by NEACH and Braid Technologies that delivers policy templates, role charters, decision matrices, and a complete collaboration playbook. The episode makes a compelling case that the institutions most at risk aren't the ones moving too fast into FinTech — they're the ones standing still while the playbook gap widens.

Guest-at-a-Glance

Kevin Johnston

• Role: Chief Banking Officer
• Company: Braid Technologies, Inc.
• Background: Former COO of Portage Bank in Seattle, which he co-acquired as an $11 million charter out of Minnesota and helped grow to over $100 million in assets. Trained as an attorney (Gonzaga Law), Kevin transitioned into commercial lending and eventually bank ownership before pivoting to FinTech infrastructure. His experience building a payments program from scratch at a community bank — including navigating regulatory scrutiny, BSA compliance gaps, and partner control failures — directly informs Braid Technologies' approach to putting banks in control of FinTech integrations. Kevin joined Braid Technologies in October 2024 to educate institutions on building internal FinTech programs.

Key Insights

The Bank Must Own the Controls — Not Just the Contract

One of the most consequential insights Kevin shares is that financial institutions have historically over-indexed on legal agreements as their primary risk mitigation tool for FinTech partnerships while under-investing in operational and software-level controls. He recounts conversations with other bank CEOs who would proudly reference their legal agreements as their primary defense — which struck him as fundamentally backward. If enforcement of a contract is your plan for when something goes wrong, the control failure has already occurred. The real safeguard is software architecture that prevents unauthorized changes — like a partner adjusting KYC thresholds without the bank's knowledge — from ever taking effect. This reframing is critical for community bank leaders evaluating their current FinTech relationships: the question isn't whether your legal team has covered every angle, but whether your technology gives you real-time visibility and rule-setting authority over the program.

FinTech Integration Is Intensification, Not Invention

Kevin makes a deceptively simple but powerful point: community banks are already doing nearly everything a FinTech partnership requires — BSA monitoring, vendor management, ACH processing, compliance reporting. The difference is one of intensity and scale, not of kind. This reframing matters enormously for the 50% of survey respondents who said they don't know where to start. The starting point isn't learning an entirely new discipline; it's asking how existing competencies need to be strengthened and scaled to support higher transaction volumes, more complex counterparty relationships, and increased regulatory scrutiny. For institutions paralyzed by the perceived complexity of FinTech integration, this insight lowers the psychological barrier to entry while raising the bar on operational rigor — exactly the right combination.

The "Paper Walls" Between Banks and FinTechs Are Thinner Than Either Side Believes

Kevin introduces the concept of "paper walls" — the mutual assumption between banks and FinTechs that the other side possesses expertise or sophistication that is, in reality, far more accessible than either party imagines. Banks assume FinTechs have impenetrable technical knowledge; FinTechs assume banks have compliance infrastructure that is more robust than it often is. In practice, most FinTechs will not have a complete application packet, will lack key compliance policies, and will need to grow alongside the bank. This mutual demystification is strategically important because it rebalances the power dynamic: community banks don't need to approach FinTech partnerships from a position of intimidation. They bring the charter, the regulatory standing, and the compliance muscle. The FinTech brings distribution and technology. Neither is complete without the other, and recognizing this creates the foundation for a genuine partnership rather than a dependent relationship.

Community Banking's Relationship Model Is Its FinTech Advantage

Perhaps the most counterintuitive insight in the episode is that the very thing community banks are known for — deep, relationship-driven client engagement — is precisely what makes them well-suited for FinTech partnerships. Kevin draws a direct parallel between managing a commercial lending relationship and managing a FinTech partner: both require consistent communication, trust built through transparency, and a genuine understanding of the counterparty's business. FinTechs want sticky, reliable bank partners they can build with over time, not transactional arrangements. Institutions that treat FinTech integration like vendor procurement will get vendor-quality outcomes. Those that treat it like their best commercial banking relationship — with regular touchpoints, mutual accountability, and long-term commitment — will build programs that generate durable revenue and defensible competitive positioning.

Episode Highlights

The $11 Million Charter That Couldn't Disclose APRs

~03:00–04:30 Kevin describes the state of the bank when his group acquired it — an $11 million institution in a town of 300 people that was producing loan documents on a typewriter and couldn't correctly disclose APRs due to outdated systems, effectively locking itself out of consumer lending entirely. The nine-month rebuild that followed — replacing core systems, documentation, and compliance infrastructure — became the foundation for everything that came after. This moment matters because it illustrates that FinTech integration doesn't require starting from a position of strength; it requires a willingness to rebuild from the ground up and a clear-eyed assessment of institutional gaps.

"This institution was a problem for the local area because with the growth in regulation, it had not been able to keep up. And so they could not disclose APRs correctly. And that meant a lot of consumer loans were actually completely off limits to this little charter when we bought it."