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Double regulation — Amendment 13 + Financial Supervision

DPO for Finance
and Fintech.

Mid-size banks, credit card companies, insurance, investment houses, lenders, fintech and crypto face Israel’s densest regulatory framework: Amendment 13 + Bank of Israel proper banking management + Capital Market Authority regulation + AML/KYC + PCI DSS. Expanded GRC support with CISO + DPO + compliance with all standards.

Regulation

Regulatory framework — who checks what

RegulatorFocus
Israeli Privacy Authority All databases, DPO, incidents, reporting
Bank of Israel — Banking Supervision Information security, cyber security, risk management
Capital Market, Insurance & Savings Authority Insurance, pension, savings companies
Israel Securities Authority Reporting, internal auditor, audit committee
Money Laundering Authority Customer records, reporting, retention
PCI DSS Every entity processing credit cards
Pain points

Six issues unique to finance

Double regulation, sometimes triple

Small bank: Amendment 13 + Bank of Israel proper management + AML + PCI DSS + sometimes GDPR if EU-active.

Bank of Israel high-security requirements

Proper Banking Management 361 requires full Information Security Management System (ISMS), internal audits, periodic reporting.

Fintech and crypto

New industry companies with evolving regulation. Combination of Amendment 13 + dedicated CMC regulation + international standards.

Credit and risk data

Credit scoring databases, payment behavior, customer opinions. Sensitive personal-financial data — specific laws on sharing and retention.

AI for underwriting

Systems automatically deciding loan / credit / insurance approval. Automated decisions = mandatory DPIA + explainability concern.

Open Banking

Clearing law, PSD2 indirectly, data sharing between banks and third parties. Requires BAA and controlled OAuth scopes.

What we do

Services fit for finance

DPO + CISO in one bench

Finance requires two synchronized role-holders. GRC + Privacy package is the right path.

Information Security Management System (ISMS)

Per ISO 27001 + Bank of Israel Directive 361. Full documentation, periodic risk assessments, controls.

PCI DSS support

For credit card processing — PCI DSS compliance, QSA audit preparation, SAQ review.

DPIA for AI and automated decisions

Impact assessment for underwriting, credit scoring, antifraud, personalization.

Supervisor audit response

Bank of Israel, Capital Market Authority, and Securities Authority all conduct audits. DPO manages the privacy aspect.

Complex incident reporting

Incident in a small bank = report to Privacy Authority + Bank of Israel + sometimes public. Critical professional coordination.

Frequent questions from finance industry

We are a small fintech — need a DPO?
Usually yes. Even a small fintech with 5,000 users = financial data processing at scale. CMC requires fintech licensing including security and privacy framework. And institutional customer tenders typically require registered DPO.

How does Amendment 13 align with Bank of Israel?
Amendment 13 focuses on privacy and DPO appointment. Bank of Israel directives focus on information security and cyber and CISO appointment. They complement. In mid-size financial organizations we offer both roles — in an integrated GRC package or via partnership with an existing external CISO.

We process credit cards — what are the requirements?
PCI DSS mandatory for anyone processing credit cards. Not a substitute for Amendment 13 — additional. GRC + Privacy package handles both standards together.

Do you have fintech / crypto experience?
Yes. We work with fintech in lending, investment platforms, digital currencies, and financial services companies. The industry requires speed and flexibility that traditional organizations don’t always provide.

What about incident reporting in finance?
More complex than standard. A security incident involving credit card data = report to Privacy Authority + Bank of Israel + payment network (Visa/Mastercard) + sometimes customers. Incident response in finance includes coordination across all parties.

How much does it cost?
Small fintech — 12,000-20,000 ILS/month (usually GRC package). Mid insurance / investment house — 18,000-32,000 ILS/month. Small bank — starts at 25,000 ILS+ depending on size.

CEOs, CISOs, CCOs — let's talk.

30 minutes, understand the regulatory framework, propose a specific roadmap.

Book a call