Philipp Shvedov

Philipp Shvedov is the Creator and Editor of DELCOS, responsible for the platform concept, the knowledge architecture, editorial standards, the topic framework, and editorial quality across the site. Insights publications under his byline start from a named failure, a regulatory development or an observed pattern, trace it back to the payment or compliance system that produced it, and connect it to the permanent pages that own those systems. Areas of work: payment systems and settlement, ledger and reconciliation architecture, Banking-as-a-Service and sponsor-bank models, KYC and KYB, AML program design, transaction monitoring, sanctions screening, and the allocation of control responsibility between banks and their fintech partners.

Publications

Practitioner NotesOctober 3, 202620 min read
Customer Due Diligence in the US: FinCEN Says Must Update, the 2018 Exam Manual Still Says Should
The Customer Due Diligence section of the FFIEC BSA/AML Examination Manual, last revised on May 11, 2018 and unchanged as of October 3, 2026, says a bank “should…
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Regulatory AnalysisSeptember 30, 202617 min read
Beneficial ownership in the US after the BOI rollback: FinCEN points to the bank’s CDD record
Since August 14, 2026, every company formed in the United States has been permanently exempt from beneficial ownership information (BOI) reporting to the Financial Crimes Enforcement Network (FinCEN),…
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Case StudiesSeptember 22, 202615 min read
The First MiFIR Transaction Reporting Fine: 46,053 Reports and One Unchecked Judgement
The FCA’s first enforcement action under the UK MiFIR transaction reporting regime turns on a single paragraph about systems and controls. One person decided which instruments were reportable…
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Practitioner NotesSeptember 16, 202612 min read
Solely a Timing Difference: The Test That Turns a Reconciliation Break Into an Exception
A difference between two records costs nothing until someone decides it will not clear on its own. Under rules that came into force on 7 May 2026, that…
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Architecture AnalysisSeptember 10, 202616 min read
Received, Cleared, Settled, Final: Who Can Still Reverse a Payment at Each State
A payment that shows as received can still be taken back. Whether it can depends on which of four states it is in — received, cleared, settled, final…
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Practitioner NotesSeptember 9, 202613 min read
No Rule Requires It: What an Alert Disposition Record Still Has to Contain
In October 2025 five US agencies answered the question directly: an institution does not have to document a decision not to file a SAR. Everything the record is…
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Architecture AnalysisSeptember 6, 202616 min read
Agent-Initiated Payments: A Shopping Layer Without a Payment Layer
Three independent counts describe the payment layer of agent-initiated commerce as at 5 September 2026. A crawler census of stores publishing the Universal Commerce Protocol finds 15,735 that…
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Case StudiesMay 6, 202619 min read
The Synapse Collapse: How a Banking-as-a-Service Ledger Failure Trapped Customer Deposits at Solvent Banks
In May 2024, more than 100,000 people opened their banking apps and could not move their money. They had downloaded fintech products — savings apps, small-business banking apps,…
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