Asia and the Middle East are the most exciting regions for fintech CISOs right now. Over the past few years, fintech markets in Asia and the Middle East have experienced explosive growth, underpinned by strong governmental support, rapid digital adoption by young tech-savvy populations, increased venture capital investment, and regulatory reforms driving financial innovation.
The UAE now leads with 686 fintech firms in 2024, followed by Saudi Arabia with 224 licensed companies. These numbers surpass KSA Vision 2030 targets. Singapore, on the other side of the world, boasts 487 fintech firms across 14 sectors, underpinned by supportive regulations. Not to mention Australia's mature fintech scene extending its geographical footprint.
Expanding into international markets is no longer a luxury but a necessity for survival in the fintech world. For example, the collaboration between fintech ecosystems in Singapore and the Middle East has strengthened in recent years, marked by partnerships such as the memorandum of understanding signed between Fintech Singapore Association and Fintech Saudi in 2024.
Nium, Airwallex, Afterpay, and many other primarily Asia-based fintech companies have either recently pursued licenses in the Middle East or set up strategic partnerships in the region over the last five years.
But as fintechs seek to expand their geographical reach, it is important to understand the specific requirements in different regions. Fintech companies operating in Singapore, Australia, the UAE, and Saudi Arabia, for example, risk substantial fines if they breach cyber incident disclosure regulations. The penalties differ significantly across these regions due to varying regulatory requirements and enforcement mechanisms. In some cases, the fines can overlap and increase the financial burden when dealing under pressure with major cyber incidents.
| Country | Maximum Fine Amount | Currency | Enforcement Context |
|---|---|---|---|
|
Singapore |
1 million |
SGD |
Financial Services and Markets Bill, Cybersecurity Act |
|
Australia |
50 million |
AUD |
Privacy Act 1988, APRA standards |
|
United Arab Emirates |
5 million |
AED |
Cybercrime Law, Data Protection Law |
|
Saudi Arabia |
800,000 |
USD |
SAMA Cybersecurity Framework |
These hefty fines emphasize the importance of robust cyber incident disclosure practices to avoid substantial financial and operational repercussions.
Moreover, the timeline and the extent of disclosure vary considerably across markets, adding another layer of complexity. The table below summarizes those expectations:
| Country | Disclosure Deadline | What Must Be Disclosed | Key Regulation |
|---|---|---|---|
|
Singapore |
Within 72 hours |
Nature of the incident, impact, and remedial actions |
Financial Services and Markets Bill |
|
Australia |
As soon as practical |
Nature of the incident, affected data, and mitigation steps |
Privacy Act 1988, APRA standards |
|
United Arab Emirates |
Within 24 hours |
Details of the incident, impact, and response measures |
Cybercrime Law, Data Protection Law |
|
Saudi Arabia |
Within 48 hours |
Incident details, affected systems, and corrective actions |
SAMA Cybersecurity Framework |
Effectively managing these discrepancies significantly influences critical cybersecurity metrics, including detection, response, recovery times, and reporting incidents to regulators and third parties.
The incessant evolution of regulations can also lead to increased operational costs and added technological complexity. Additionally, the pressure to meet stringent reporting deadlines can result in significant stress and burnout among cybersecurity teams in a market already facing a shortage of skilled professionals.
Given these pressing matters, how can fintech CISOs sleep better at night and feel more in control? Below are shared proven strategies that mitigate risk and boost regulatory compliance across countries.
Engage Early with Regulators and Industry Peers
Fintech CISOs must participate in regulatory consultation groups and fintech associations to gain early visibility into upcoming disclosure mandates. These forums also serve as powerful platforms to advocate for pragmatic, risk-based approaches that reflect operational realities.
Consider this: In early 2023, Circle, the issuer of USD Coin (USDC), began aligning its cybersecurity posture with emerging expectations around threat detection, incident disclosure, and operational resilience. Following widespread disruptions triggered by the Silicon Valley Bank crisis — which exposed the digital asset ecosystem's dependency on centralized infrastructure — Circle accelerated its internal risk assessments, including cyber threat scenarios tied to service provider outages and data continuity breaches.
Its legal, compliance, and security teams later contributed to industry discussions that shaped the Token Capital Adequacy Framework (TCAF), a policy model submitted to regulators that incorporates cybersecurity risk as a core operational criterion. This emphasis on cyber-driven stress scenarios allowed Circle to advocate for disclosure frameworks that balance transparency with pragmatic resilience planning, especially for blockchain-based financial services. Though formal consultations with the SEC and Treasury remain undisclosed, Circle's proactive engagement helped inform broader regulatory conversations.
By the time the SEC finalized its cybersecurity disclosure rules in late 2023, Circle had already embedded incident reporting timelines, cross-functional coordination, and risk quantification into its compliance program — reinforcing its credibility with regulators and positioning it as a forward-leaning industry voice with customers.
Establish Cross-Jurisdictional Cyber Fusion Teams
Fintech CISOs should build cross-functional surveillance teams spanning cybersecurity, fraud, financial crime, and physical security. These multidisciplinary teams, ideally enhanced by AI-driven tools, can rapidly analyze threats, evaluate business-critical risks, and accelerate threat detection and remediation—essential for meeting timely regulatory disclosure obligations.
Consider the following case study. A global fintech payments provider struggled with fragmented vendor risk management and slow security assessments across its growing supplier network. Disconnected cybersecurity, legal, and procurement teams made it hard to respond quickly to evolving threats and compliance requirements.
To fix this, they adopted a leading SAAS security and compliance platform, enabling real-time cybersecurity monitoring and streamlined vendor assessments. This integration fostered collaboration across teams and improved visibility into third-party risks. The result was faster vendor risk assessments, better regulatory readiness, and a shift toward proactive, cross-functional security governance, reducing risk while improving operational efficiency.
Institutionalize Cross-Border Cyber Risk Culture Through Regular Cyber Crisis Exercises and Training
It's equally important for fintechs to conduct regular, realistic cyber crisis simulations that include third-party scenarios and regulatory reporting drills.
Those exercises are a great opportunity to pressure test the existing compliance framework and as well as the, as automated as possible, evidence collection process.
The ultimate goal of those exercises in term of regulatory disclosure management is to check, under pressure of a major incident, if the fintech organization can deliver consistent, timely communications and disclosure when dealing with added complexity of cross border stakeholders' engagement internally to the fintech (several departments and the board) and to external stakeholders (including key third parties, regulators, and the press).
Furthermore, fintechs must ensure that lessons learned are systematically embedded into process improvements, tooling upgrades, localized playbooks, and team training.
Cyber incident response tests must go beyond obligation—to sustain engagement, they must be culturally relevant and drive ownership from top business officers.
Map and Monitor Critical Third Parties
Cybersecurity teams diligently identify third-party vendors that pose significant cyber risk and co-develop threat assessment protocols, communication frameworks, and remediation SLAs.
In April 2025, Toppan Next Tech (TNT), a critical printing vendor for DBS Bank Singapore, suffered a devastating ransomware attack. The breach compromised approximately 8,200 DBS customer statements, primarily affecting DBS Vickers investment accounts. This incident exposed a significant vulnerability in DBS's third-party risk management framework, highlighting the cascading impact of vendor breaches on financial institutions.
Following the attack, Singapore's Monetary Authority (MAS) required immediate disclosure and remediation. DBS's response revealed that while they had regulatory compliance measures, their third-party risk mapping had overlooked critical dependencies on TNT's cybersecurity posture.
To mitigate this key risk, fintech CISOs must consider three key recommendations:
- Conduct Rigorous Onboarding Due Diligence: Assess new suppliers' security posture using threat intelligence, compliance checks, and financial stability reviews before engagement.
- Mandate Robust Security Assurance: Require evidence of ongoing controls (e.g., SOC 2, ISO 27001) and breach notification obligations as part of standard contract terms.
- Embed Regulatory Disclosure Clauses: Include contractual provisions that compel suppliers to notify your organization of any incidents affecting shared systems or data within mandated timeframes.
Looking Forward
Security is no longer a nice-to-have for fintech startups. By embedding proactive risk management, robust third-party oversight, and clear regulatory alignment into their operations, fintechs can not only stay ahead of compliance requirements but also build trust with customers, partners, and regulators.
