Leading a real-estate crowdfunding platform through its EU licence audit, as COOLeading a real-estate crowdfunding platform through its EU licence audit, as COO

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.

• 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.

• 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.

1. 00

   Oct 2022

   Joined as COO: a platform with a product and no licence, in a regulated market.

2. 01

   Authorisation file

   Penetration testing, the architecture review and the policy set the regulator examines: risk, complaints handling, conflicts of interest, business continuity and outsourcing.

3. 02

   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.

4. 03

   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.

5. 04

   Operations

   Approval flows, exception handling, investor support and regulatory reporting, run on the KPIs and cadence Adrian set.

6. 05

   25 Mar 2024

   ASF decision: the ECSP licence is granted. Romania's fourth, and the second for real estate.

7. 100

   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.

• 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.

• 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.

• ECSP, Regulation (EU) 2020/1503
• LemonWay (PSD2)
• KYC and AML
• Penetration testing
• Policy set and regulatory reporting