Products / Market Entry Matrix
Build the regulatory footprint around the business, not the other way around.
A new market does not always mean a new entity and another full license. The Matrix combines regulatory expertise, commercial strategy and structured market analysis to map the compliant routes to your customers. We compare not only where you can operate, but how: direct license, cross-border access, partner, agent or introducer, acquisition, regional hub or phased entry.
Who it’s for
For the decision before the decision.
- A firm about to apply for a license that has not yet asked whether it needs one.
- A business entering the United States, the United Kingdom, the European Union or another market for the first time.
- A group expanding into several countries that would rather not build a separate license and compliance operation in each by default.
- A board or investor asking for the expansion case, and its alternatives, in one document.
What you get
What you receive.
Not a legal answer. A regulatory strategy for the business, written to be put in front of a board.
The Matrix
Target markets and the routes into each, side by side on the same dimensions.
Recommended regulatory architecture
The combination of entities, licenses, partnerships and other permitted arrangements that best supports the strategy.
Regulatory and commercial heat map
Opportunity, burden, complexity, cost, timing and risk, compared at a glance.
Route-to-market analysis
What each structure permits, what it requires and what it restricts.
Time-to-revenue and cost view
The realistic path from decision to operating business, and the initial and ongoing cost of maintaining the structure.
AML and sanctions overlay
How the proposed customer, geographic and transaction footprint changes financial crime exposure.
Expansion roadmap
Now: the markets and structures to prioritize. Next: expansion once defined milestones are met. Later: opportunities worth preserving without premature investment. Not yet: markets where the burden or the risk outweighs the value today.
Executive decision session
A working session with senior Taft practitioners to challenge the assumptions, compare the alternatives and agree the strategy.
Options
Three depths.
Timing depends on the number of jurisdictions, products and regulated activities, and on the complexity of the structures under consideration.
Market Entry Focus
- One business line and a small number of target jurisdictions
- Typically one to two weeks
Market Entry 360
- Multiple jurisdictions with alternative licensing and market-access strategies
- Typically two to four weeks
Global Regulatory Architecture
- Multi-entity, multi-product and multi-region expansion
- Or the simplification of an existing footprint
- Typically four to eight weeks
Routes, not just countries
Do you need another license at all?
A conventional market-entry study tells you that one jurisdiction is faster and cheaper than another. The Matrix asks a different question first, then evaluates every viable compliant route into each market and its trade-offs. Not every route works in every jurisdiction. Finding out which do is part of the work.
Full license
The most local capability, at the greatest cost and with the heaviest continuing burden.
Cross-border
Where the law allows it, serve the market without duplicating infrastructure.
Partner model
Reach the market through an appropriately regulated local institution or provider.
Agent, introducer or tied agent
Where permitted, a properly structured relationship that reaches customers without replicating a whole regulated operation.
Acquisition
Buy an existing regulated business where the commercial and regulatory case supports it.
Regional hub
One well-chosen regulated entity supporting a broader regional strategy, where permitted.
Phased entry
Test demand through a lighter route before committing to full authorization.
What we assess
Ten dimensions, the same for every market and every route.
Every Matrix is configured around your business model, products, target customers, current licenses, growth strategy and risk appetite.
Market opportunity
Customer opportunity, commercial priorities, distribution model and expected revenue.
Regulatory perimeter
Which activities trigger regulation, which licenses or registrations may be required, and what can be done without separate authorization.
Routes to market
Full authorization against the compliant alternatives: partnerships, agency and introducer structures, cross-border models, acquisitions, regional hubs and phased entry.
Regulatory burden
Capital, substance, local management, chief compliance officer and MLRO requirements, governance, reporting, audit and ongoing supervision.
Time to revenue
Not how long authorization takes, but how soon each structure can realistically begin doing business.
Total cost of ownership
Application and set-up costs, and the ongoing cost of entities, licenses, people, governance, systems and obligations.
AML and sanctions exposure
Customer and geographic risk, sanctions exposure, cross-border flows, correspondent and payment relationships, and financial crime requirements.
Banking and infrastructure
Whether the structure can obtain banking, payment rails, custody, clearing, insurance and the other relationships it depends on.
Reputation and regulatory credibility
Whether a structure that is technically permissible will also be credible to customers, investors, banks, counterparties and future regulators.
Future flexibility
Whether today’s structure supports tomorrow’s products and markets, and what it would cost to change or exit if the strategy moves.
What makes the Matrix different
Regulatory advice usually starts with the license. We start with the business objective.
Regulatory expertise
What is required by law and by the regulator.
Compliance experience
What it will actually take to operate and maintain the structure.
Commercial judgment
Whether the regulatory investment makes sense against the opportunity.
Cross-border perspective
How the entities, licenses and markets work together rather than one at a time.
Financial crime perspective
What AML, sanctions and customer risk the proposed footprint creates.
Implementation experience
What looks simple on paper and becomes expensive or difficult in operation.
When to use it
Seven moments when the route matters more than the destination.
Before applying for a license
Confirm it is the best route before committing time and capital.
Before a new market
Understand the regulatory architecture before establishing entities in the United States, the United Kingdom, the European Union or elsewhere.
When expanding into several countries
Avoid a separate license and compliance operation everywhere by default.
Before launching a new product
See how the product changes the regulatory perimeter and the markets available to you.
When the strategy has changed
Reassess licenses, pending applications and entities that may no longer serve the plan.
After an acquisition or investment
Work out how existing permissions can support the combined growth strategy.
When regulatory cost is too high
Simplify the footprint without giving up compliance or market access.
A worked comparison, hypothetical
One business, three routes into the United States.
Everything in this example is hypothetical: the business, the assumptions and the reading. It shows how the Matrix weighs routes against each other. It is not advice for any real firm and it is not a legal conclusion. It has no cost or timing figures, because in a real Matrix those depend on the firm’s own facts.
The business
Hypothetical. A payments company authorized in the United Kingdom offers business accounts that pay overseas suppliers. It wants US importers as customers. It handles no cash and has no US entity. Its board wants revenue from US customers before it funds a full US build.
Assumptions
The company’s UK authorization gives it no permission in the United States. At least one US bank will discuss a partnership for this product. The customers are spread across several states. The product stays as it is while the routes are compared.
Route A: direct license
A US entity offers the service itself. If it is a money services business under FinCEN’s rules, it must register with FinCEN whether or not a state has licensed it, and it must develop, implement and maintain an effective anti-money laundering program, in writing and commensurate with its risks. These are binding federal rules. The state money transmission licenses its footprint needs are a separate question. The route gives the most control over the product and the customer, and carries the heaviest continuing burden. Source: 31 CFR 1022.380(a)(1) (eCFR, up to date as of November 5, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-C/section-1022.380. Source: 31 CFR 1022.210(a) to (c) (eCFR, up to date as of November 5, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022/subpart-B/section-1022.210
Route B: bank partner
A US bank holds customer funds and provides the account. The company supplies the technology and the customer experience under the bank’s program. The lightest build for the company, and the least control: the bank decides the customer types, the corridors and the pace. Whether the company’s own role still needs a registration or a license is a question for counsel, not an assumption.
Route C: phased entry
Start on Route B for a defined customer segment. Agree in advance the triggers for moving to Route A: corridors or customer types the bank will not support, or a product the partnership cannot carry. Build the compliance program and records to the Route A standard from the start, so a later move does not mean rebuilding them.
Disqualifiers
If the company itself accepts customer funds and transmits them at any point, it may be a money transmitter in its own right, and Route B no longer describes the business. FinCEN’s binding definitions describe money transmission services as the acceptance of funds from one person and their transmission to another location or person by any means, and say that whether a person is a money transmitter is a matter of facts and circumstances. A money services business can be a person wherever located doing business wholly or in substantial part within the United States. Routes B and C fail if no bank will accept the corridors. Route A fails if the board will not fund a US compliance function before revenue. Route C fails if the bank agreement prevents moving customers later. Source: 31 CFR 1010.100(ff) and (ff)(5) (eCFR, up to date as of November 5, 2026), https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-A/section-1010.100
What local counsel confirms
Whether the company or its US entity is a money services business on its actual facts. Which state licenses Route A needs, and on what conditions. Whether the company’s role under Route B requires a registration or a state license anywhere it operates. Whether the bank agreement allows the move Route C depends on. Until counsel confirms these points, the comparison is conditional.
How it reads
Hypothetical. On these assumptions Route C reads best: revenue can start under the bank’s program while the company builds toward its own license. Route A comes first instead if control of the customer matters more than time to revenue. Route B alone reads weakest, because the board’s plan needs corridors the bank may not support. None of the three routes is a finding that a license is unnecessary. Change one assumption and the order can change. That is why the assumptions are written down.
How it runs
How it runs.
Understand
We start with the business: products, customers, target markets, revenue model, distribution, existing entities and licenses, growth plans and risk appetite.
Map
We establish the regulatory perimeter and the available routes to market in each target jurisdiction.
Challenge
We test the original assumptions. Do you need this license? Why now? What does it actually allow? Is there a faster compliant route? Will banks support the structure? What happens if the commercial strategy changes?
Model
We compare the alternative structures on commercial opportunity, regulatory burden, cost, timing, sanctions exposure, operational complexity and future flexibility.
Design
We recommend the combination of entities, licenses, partnerships and market-access arrangements that best supports the strategy, and present it to your management or board.
Questions
Asked before, answered plainly.
- Is the Matrix a legal opinion?
- No. It is regulatory strategy from compliance practitioners who have licensed and operated businesses in the markets compared. Where a legal or tax opinion is required, we coordinate with your advisers and build their conclusions into the Matrix.
- Which markets can it cover?
- Any market where you are considering operating. The routes and the dimensions are the same everywhere; the answers differ. Where a jurisdiction is unfamiliar to us we say so and bring in local expertise.
- What if the answer is that we do not need a new license?
- Then that is the answer, with the route that gets you to your customers without one and the conditions under which it stops being enough. Fewer licenses is often the better outcome.
- How do you compare jurisdictions for a fintech?
- Route by route, not only country by country. For each target market the Matrix sets out the compliant routes into it, then compares them on the same ten dimensions, from the regulatory perimeter to future flexibility. The hypothetical worked comparison on this page shows that reasoning on one business. It is not legal advice; where a legal opinion is required, we coordinate with your advisers.
The Matrix is regulatory strategy from compliance practitioners. It is not legal or tax advice; where those are required we coordinate with your advisers.