Fintech Layer Cake
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Fintech Layer Cake
A Primer on US Fintech Expansion with Klaros' Andy Kampf
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What actually breaks when a fintech expands to the U.S. — product, licensing, hiring, or assumptions?
In this episode, host Reggie Young sits down with Andy Kampf, Partner at Klaros Group and former Klarna US legal lead, to unpack the real framework behind cross-border fintech expansion. Andy breaks down the four pillars every foreign fintech must get right — product, bank partnerships, hiring, and budget — and the hidden pitfalls that derail U.S. launches. From misconceptions about European e-money licenses to choosing the wrong bank partner, Andy shares practical insights drawn from advising global fintechs entering the U.S. The conversation also dives into cultural underwriting differences, lessons from Klarna’s speed-first model, and what Europe’s proposed “28th regime” could mean for startup migration and capital flow. A must-listen for fintech leaders thinking seriously about international expansion.
Reggie Young: Welcome back to Fintech Layer Cake, where we uncover secret recipes and practical insights from fintech leaders and experts. I'm your host, Reggie Young, Chief of Staff at Lithic. Software has been eating the world since before Marc Andreessen wrote those words in 2011, and digital payments have increasingly been part of that trend. The worldwide cross-border nature of money movement isn't new, but I expect it'll be a bigger and bigger theme in 2026. We're definitely seeing this firsthand at Lithic, where we're working with enterprise customers investing in global expansion to the US or moving beyond US borders. As a result, I've been thinking a lot about fintech companies that operate across-borders lately, and there's no better person to jam on that topic with than Andy Kampf.
Andy is a partner at the bank and fintech consultancy, Klaros Group. He focuses on advising fintechs and banks looking to expand to the US. Before Klaros, Andy worked at Klarna, where he led US product legal and regulatory strategy, dealing with the cross-border expansion questions at a time when the company underwent extensive growth. Given Andy's background, I was excited for this conversation since he's one of the sharpest minds in fintech to ask about seeing around corners when a fintech is expanding internationally.
Fintech Layer Cake is powered by the card-issuing platform, Lithic. We provide financial infrastructure that enables teams to build better payments products for consumers and businesses. Nothing in this podcast should be construed as legal or financial advice.
Andy, welcome to the podcast. Super excited for our conversation today. This was kicked off by a piece you wrote back in November of 2025 that was aimed at fintechs considering entering the US. I thought it was an excellent piece, both concise and it very clearly spoke to your firsthand experience grappling with cross-border questions and expansion. I love to start out our conversation with that piece. My initial question is for a fintech that wants to expand to the US, what's your framework of thinking through that? It's a big nebulous, cross-functional problem. How do you help add structure to that move?
Andy Kampf: Yeah. First of all, thanks for having me, Reggie. I'm a longtime listener, first-time attendee. As far as your question, it's complicated, it's complex, and there's steps in the process that I've developed that can be really helpful. But as a starting point, just having certainty and clarity is really what a lot of these foreign fintechs are looking for naturally. It's the US market. It's huge. There's a lot of opportunity. But it's also just, as you said, very nebulous. So if I can get certainty and clarity for my clients, then I think that goes most of the way towards success. As good as the product might be in the home market and as good as the people are in the home market, there's a lot to grapple with in the US. It's important to be able to dispel any assumptions that might be wrong or just misguided and to explain some of the nuances in the US market that can really get a lot of players tripped up.
I think for myself and for you as well as attorneys, or recovering attorneys, there's an analogy for me or just a similarity to if you're practicing law and someone says, hey, can you pick up this real estate problem, or even with state-by-state jurisdiction. Sometimes, I don't know about you, I don't practice in Delaware even though I'm based outside of Philadelphia, and Delaware is very specialized. So I think it's the same. If you have a great product in Germany, that doesn't automatically mean it's going to translate into the US, or at least that you'll know everything that needs to go into it just because you're an operator there in another country where you've had success.
So with that in mind, there's really four pieces to the framework as I see it that I'll walk through. Certainly, the product is important. Ultimately, the bank partner side of things is really important. There are some companies that it's going to make sense to maybe pursue your own bank license or to pursue more of a state-by-state licensing regime. But for a large majority of the companies, it's going to be around the bank partnership. I can talk about that.
Reggie Young: Quick shout out for Klaros there. Folks should go check out the Bloomberg article that recently came out with the title, if you want to become a bank, these are the people to talk to or something. Something along those lines came out in early January, I believe.
Andy Kampf: Yeah. It’s in the February print edition of Bloomberg. But yeah, great piece. We're obviously thrilled with it. Konrad and Michele prominently featured, but really huge accomplishment for Klaros and just great publicity. So thanks for that.
So yeah, some companies want to become banks, but a lot of them are going to partner with the bank. The third piece is really the hiring plan, and the fourth is around your budget and your timeline. So going one by one, the product is most important. A lot of the types of questions I'm going to ask, is there more of a simpler or the simplest kind of MVP of your product, right? Because a lot of times, it's going to make more sense to go start with that and build on that, not so much beholden to it needs to be, from day one, exactly the way it is in every other market. Some companies might really want to do that and might really insist on that, but it's probably going to be just better all around if you can go with an MVP approach and build on that.
Reggie Young: And to your earlier point, that MVP approach lets you find the differences or at least tweak your product more easily as opposed to like, oh, let's build a bank account that worked in Europe for the US when people may not want the same features. So start with the MVP, you get a little more flexibility. You don't get locked into a certain feature.
Andy Kampf: Right, and versus the inverse of you do launch it exactly the way it is, and then you might have to run into those problems, pull something back from the product. That's a lot harder, I think, than having the MVP and then making those decisions of maybe it doesn't make sense to add this feature because there is this nuance in the US that we didn't really appreciate until now. So there's that.
And then otherwise, for product, I think, making sure that there's alignment on what the target demographic is. And also maybe the very first question is really, what's your competitive edge? Why do you think this is going to succeed in the US? Because that type of question early on can often lead to what you just mentioned, too, where maybe the edge is something that's unique to your market or there's some nuance in the US that is going to make that not as appealing, maybe more appealing, or maybe there's some pivot there, but understanding why you're so confident in your product expanding to the US beyond just, well, it's the US, there's a few hundred million people here and so much capital. It has to be more than that.
Reggie Young: Yep. There's a graveyard of neobanks that have tried to expand to the US. There's also some that have definitely done it, I think, to your point, because they had that strategic question figured out early.
Andy Kampf: Yeah. That line of questions gives us a good starting point and a good sense of the product. As I mentioned, the bank partnership, I think, is the next phase of it. There's a lot that goes into that, obviously, and a lot of it that you can't necessarily cover up front until you dive a little deeper. But at least at an initial point, it's understanding what product you have. First, do you already have a bank partner in mind, or do you have any relationships at bank partners? A lot of fintechs might have something they've read, something they've heard about a particular bank, and they are really dead set on working with that bank. It might not be the right fit for them. So it's important to understand where they're coming at from that point of view and, again, informed by what your product is, what your MVP is, and the demographics are, and all those features that we talked about.
Third is really around hiring. That's critical. Some companies are coming in and they might already have some boots on the ground. But assuming that you're coming in fresh, generally, my recommendation is there's a few important roles. One, maybe the most important is just around go-to-market in the US, having a US general manager, and one who's familiar with the specific industry and who can really get you customer number one, a handful of prospects right off the bat that are going to be meaningful to you, have those connections. Maybe even better if they have a team in mind or other hires in mind that they've worked with before. You build off of them, then that goes a long way.
Also, legal is going to be really important. For a lot of new-to-the-market fintechs, I think you can certainly get by with a fractional general counsel early on. But similar with the GM role, it's really important that they are specialized, that you do the diligence and figure out, that they know what they're talking about, specifically, not in the more general sense. We in legal, and a lot of industries, you might be a fintech expert on paper and come to find out that you're trying to launch a card product, and this is a really an expert in the deposit space, just as an example.
And the third role is really just product. You need to have someone who can build the product and refine the US-specific product for you. If you build out those three, from there, there's more roles that are going to come into play. But I think from a starting point, those three are really pivotal. It's important to not rush through the diligence here, like I said. You want to, for all those roles, be able to say that they're be able to understand that they are the experts in this specific product for you. Klaros, in particular, I think, is really excellent in that regard because we have such a deep bench of experts and of senior former executives within our ranks. It serves a couple of purposes.
We also have Klaros Talent, which is just an outright can help you with the hiring process itself, and that's critical and relatively new for Klaros. In addition to that, just having the former bank CEOs on staff who can- maybe they'll help interview, maybe they can help with, once you have people onboarded, just with filling in some of the gaps. I've used the term like a mirror C-suite where you can- some of the Klaros folks and you have your own folks and put them together as needed for critical questions along the way.
The last point- we've talked product, bank partner. We've talked hiring. Last one is around just timeline and budget, really just alignment on that. I think that from a timeline perspective, it can really vary depending on how developed you already are on the ground versus not. From a budget perspective, though, I think more importantly- the US is expensive, and I think especially from a hiring perspective, a lot of European companies, there's a lot of sticker shock when it comes to salaries. But what I really strongly caution advise is if you picture yourself 12 months from now and you're missing deadlines and your product is just not getting off the ground and you come back to today where you could have just spent another 200,000 on the right hire in this role, you would do that every time.
Reggie Young: Yep. I love you mentioning legal is an important in early hire, because there's so many instances I've seen in fintech of companies burning like six months because they didn't get the right counsel. They didn't hire somebody that knew the space. They got the answer from Claude or ChatGPT or whatever and just ran with it. But they end up burning four to six months of resources before they realize, oh, we actually can't do it this way. We didn't find the right expert. So it matters a lot. It saves you a lot.
Andy Kampf: Yeah. And it's so unfortunate when it happens, too. It's too late when you realize it that you hired the wrong person.
Reggie Young: Yep. Cool. Awesome. I love that. That's a useful framework. Again, it's a super nebulous problem. So that's some great starting points for folks. I'd be curious what some of the most common pitfalls are from fintechs that expand to the US. As we alluded to the graveyard, there's a graveyard of failed US expansion. So how do you help? What are the corners to help fintech see around that you've seen from your experience?
Andy Kampf: Yeah, there's a few. Some of them are surprising just, I think, probably to you or me or to some others in the industry because they seem so fundamental. But it shouldn't be surprising because I don't think that I would know the first thing about entering a lot of markets. But one thing that I've seen from a couple of different companies is they have an electronic money license in Europe, and they have a misunderstanding of what that gets you in the US. It doesn't really get you much at all, but there's an assumption that, oh, I don't need to go down the MSB/MTL route. I don't need a bank partner. I can be a principal member of the Visa card network. And really, like none of that is true. You need to still go through all those routes.
Reggie Young: It's such a funny thing. If you grew up in US fintech- I definitely went through this phase where I realized that it's so different outside the US, the bank partner model. Bank partners are not as critical as vendors as they are as partners as they are in the US as in most of the countries. Yeah, you get the flip problem when you're like, wait, I need a bank, I can't just go be a member of Visa or Mastercard directly.
Andy Kampf: Yeah. You mentioned bank partners, and I think that's a big one, too. Most fintechs have heard enough to say, oh, we think we need to enter through the bank partner model, but there's rarely a full appreciation of what that entails and why we need it. And I think once a lot of these companies understand why, and going back to you're not a bank- if you're a bank in another country, it doesn't mean you're a bank here, and you need to be a bank to do these certain things, and the whole true lender framework. Just giving some background on that is always really enlightening to these foreign fintechs. It's just a foreign concept naturally.
Reggie Young: Yep. It's such a straightforward concept, too.
Andy Kampf: Let's see. On the bank partner, too, I alluded to this earlier, but I think choosing the right bank partner or choosing the wrong one and having- like I said, I think a lot of companies might read about one or more banks who are partnering with big-name fintechs and so that's who they want to work with. They might not be right for your product. They might not have capacity right now or to be able to launch in the timeframe that you want to launch at. There might be others that are just as suitable and have the time for you now. They might not have just general expertise. They might be new to the partner banking.
The one caveat I'll say there, though, is we're seeing more and more banks wanting to get into partner banking and fintech partnerships. I think that's great, and I think there's an opportunity, and I think there's also a lot of these banks who are doing it right. As a fintech partnering with one of those banks, maybe while they're themselves ramping up, it can give you a little bit more, say- you can teach them a little bit and guide them on how the processes should work and how you want them to work and how you envision them more so than going to one of these established players that say, we've been doing this for 5, 10 years. We have all these dozens of partners and works just fine for them, so we're not going to reinvent the wheel for you.
Reggie Young: Yeah, that's a super important point that I haven't seen written or talked about a lot. But increasingly I'm getting the impression that there are banks getting into fintech, but it's different than banks getting into fintech four or five years ago. We have this nice history of consent orders in the US where now you can go and you look and say, hey, here's the checklist of what at least the prior administration's regulators would want you to triangulate from those consent orders, what sort of best practices are going to be. There are more banks getting into it, but there's definitely a lot more banks that are investing up front, they understand, because they're working with folks like the folks at Klaros or others to figure out like, what do we actually need to do as opposed to, let's just put a landing page and start talking to fintechs. They're making the right investments, which I think is really exciting because banks are now setting up a really good foundation for their partnerships in the US.
Andy Kampf: Yeah. Those are some of the main pitfalls. The one other that I get a kick out of, and I saw it at Klarna and I see it now, is it's only slightly hyperbole to say that some of these European populations just feel like deep personal shame if they're not paying debt on time. They skip meals and pay off a small loan that they have. And Americans are just much more comfortable with debt and delinquency and credit in general. It factors in- you really have to drive the point home multiple times with lenders coming from other markets that you need to build the different cultures into the front end of your underwriting and also the back end with your collections, your repayments forecasting, whatever it may be, that it's going to look meaningfully different than it looks in some of these other markets.
Reggie Young: Yeah, that's fascinating. I hadn't heard that before. Speaking of your Klarna experience, would love to chat about that briefly. What were some of your top lessons from your time there?
Andy Kampf: Yeah, Klarna was great. I was there for almost four years handling kind of all things US legal. The market entry, that's translating to my role now as well. Coming from- I'd been at JPMorgan prior to that. And I think going into Klarna, one of the things was just like, I can't assume anything, which is, I think, true. Maybe, in general, if you're coming from such a large, established player and going to a smaller, faster fintech, you can't assume anything. You have to ask the stupid questions and the number of times that I would raise my hand, raise my voice, and then so many other people on the call would have that same issue or same question, or there'd just be a real misalignment that wouldn't have come to light otherwise.
One of the things I learned or experienced was just the incredible speed at Klarna, again, coming from Chase and going to Klarna. You can imagine, and I saw this from day one, I saw it throughout, it was with new products, new features. In 2024, when CFPB implemented the BNPL rule, and we had to spin that up quickly and figure out how it applied to existing products, how it applied to products that were in the pipeline, it was incredible to see that speed, and it was often very effective.
But I saw both sides of it for sure as well, where sometimes it was just trying to do everything all at once and as fast as possible. And sometimes you could see where a little bit more focus and narrowing of offerings can be more valuable. I don't think that's uniquely Klarna either. I think that's a lot of fintechs we see, where, try this, try that, which thing sticks. You hit the ground running.
Reggie Young: Yeah, it's interesting to me because I think, at least from what I've seen, the sort of two themes that you mentioned there of assume nothing and ask the stupid questions and speed, it's like you have to assume nothing and ask stupid questions because you're moving so fast, and the context on things isn't always shared out and people- like there's not the slowdown process, bureaucratic process, to align on things. So it's interesting. I never thought about that, but it is two sides of the same coin.
Andy Kampf: Yeah, you're right. They do all go hand in hand. Yeah. When you're going from concept to MVP in a matter of weeks or a couple of short months, that's going to happen. It was interesting, but incredible experience, great people. Miss my Stockholm trips and trying reindeer with lingonberry sauce. I'll have to get back to Sweden first with some other excuse at some point.
Reggie Young: I love it. So yeah, you work with a bunch of fintechs. You've got a good seat for the trends that are happening, particularly in US expansion, but just generally in fintech. What trends are you expecting to see over the next two years? What's coming in 2026 and 2027 from your vantage point?
Andy Kampf: One thing that I've been paying close attention to is what's referred to as the 28th regime in Europe. I don't know if that's something that you're familiar with or you've heard of.
Reggie Young: Generally new to me and I'm sure new to a lot of our listeners, so would love to crash- I'm assuming nothing here. I'm taking your advice. I’m assuming nothing.
Andy Kampf: In Europe, it's much different than the US in a lot of ways. But in one way is each of the 27 main countries in Europe have their own kind of regime for registering a new company, and that comes with different laws around how you can treat stock options and taxes and labor, wide range of issues. And it's been a growing pain point over the years.
Finally, in the past year or so, there was this grassroots effort from the start-up community and the fintech community that there should be just one unified option. It's not going to solve all those problems because some of the countries feel really strongly about labor laws, for example, that you can't just bypass all that. But the idea, I've heard it talked about as like a European Delaware. Everybody historically registers in Delaware because the laws are the most favorable. Conceptually, this would be the same idea in Europe.
The grassroots effort I mentioned gained so much momentum over the past year that it made it onto the European Commission's legislative calendar, which was a feat in its own right. And then just last week or last couple of weeks at Davos, the president of the European Commission specifically referenced the 28th regime in her speech. That was an even bigger feat because it's definitely happening, right? So I think that'll be a real make-or-break issue as far as how it actually passes.
But one of the major things that I didn't hear her say and that I'm still watching closely is it can take the form of either a directive or a regulation. And a directive is really, hey, 27 countries, you all each need to implement the spirit of this, versus a regulation is this is what you have to implement, exactly this. It sounds to me- or I haven't heard anything otherwise and I'm still skeptical that it ends up being a regulation. If it's a directive, then it's almost the same such like it's the status quo with a new name. And if that happens, I could see more companies just being fed up and just leaving.
They're having the hardest time with early-stage companies who either can't properly compensate through stock options their early talent, or that same talent ends up paying huge taxes on options that they won't be able to do anything with for several years. It can be prohibitive in some instances, and it drives companies out of Europe. I'm following that real closely to see how it plays out. I think there'd be potential capital exodus and just a brain drain out of Europe if it's not implemented in the right way, which is, by the way, as a regulation.
Reggie Young: Yeah, Interesting. I'm thinking of the Money Transmission Act, which almost all states have money transmission laws. A lot of them vary in some way, some capacity, but there's been this attempt to standardize money transmission laws across states. You can opt into this. And so every state has passed it with some variation, like you end up with a 90% overlapping Venn diagram, but then you still have to deal with all the state quirks. And of course, it's going to take decades for it to get even decently aligned across states. So not actually that practically- a good idea in theory, but in practice, it's ended up not being that useful. Hopefully, it ends up being more of that regulation idea.
Andy Kampf: Yeah, and I think that's a great analogy, and it's the same concept of the states and the European countries trying to do their own thing in the same spirit versus a federal law in the US with preemption and everything as would be closest to a regulation in the EU that's going to apply directly and require that it be in a specific strict format instead of more optional.
Reggie Young: Yeah. Awesome, Andy. Loved our conversation. I've got my standard wrap-up questions for the last few minutes here. What have you been thinking about a lot lately that you think folks in fintech aren't talking about enough?
Andy Kampf: Is anyone talking about agentic commerce?
Reggie Young: I haven't heard much about agentic commerce and stablecoins. There just hasn't been that many headlines about it.
Andy Kampf: A couple that come to mind. People are talking about this, too, but just the CFPB enforcement. What does that mean?
Reggie Young: All virtual.
Andy Kampf: Right, and a much smaller footprint, but there's still enforcement. What direction does it go? What happens with fair lending? Disparate impact enforcement and examination around that, and then just a little bit longer-term whiplash, whiplash after midterms or the next presidential election. Companies can't lose sight of that. But it makes it really challenging to say, we want to grow, we want to be more aggressive, but in a reasonable cautious way. But then will that- you can only know so much about what's going to happen, what the next administration will do. So I think that's just something to watch and something that any kind of tea leaves that we can read, we're trying to get ahead of that.
Reggie Young: Yeah. This is one of the points I've been harping on a lot lately, is there are some areas where I think that the regulatory window is open a bit. Like bank charters, for example, is it's a unique time at the OCC level to try and go get an OCC charter. But when you're looking at the statutes that the CFPB enforces, a lot of states have analogous statutes, and there's this seesaw historically of when the CFPB backs off on enforcements, California and New York step up on those enforcements.
And so it's a whipsaw that's not productive in the way most people think it is in terms of, oh, the CFPB regulatory window is open. It's like, no, you're still going to get sued by California if you do that thing. You're still not going to be able to ultimately serve residents in California or residents in New York, which, by the way, are large markets. So is it really that much of a boon? And so instead you're dealing with this whipsaw of you may have a state statute that's enforced slightly differently than the CFPB would enforce their analogous powers. It ends up being like just a quagmire that's not as useful. Most people, I think, are getting excited about the current regulatory environment. I'm like, guys, it's not that simple. It's not like open season to go do whatever you want.
Andy Kampf: Yeah. Careful what you wish for.
Reggie Young: Yeah. Awesome. Well, Andy, if folks want to get in touch or learn more about Klaros, where should they go?
Andy Kampf: Yeah, absolutely. I'm on LinkedIn. You can also get me at andrew@klarosgroup.com and feel free to reach out.
Reggie Young: Like I said at the beginning, Andy puts out some great articles. Go follow him on LinkedIn so that those articles get posted in your feed. Andy Kampf, K-A-M-P-F. Go follow him on LinkedIn. He puts up great stuff.
Andy Kampf: Yeah. Thanks, Reggie, and thanks for having me.