A $2M Contract Sitting on a Compliance Blocker
The head of partnerships at a fintech API company had spent four months negotiating a contract with a regional bank. The terms were agreed. Legal had signed off. The bank's security team had one remaining requirement: a SOC 2 Type II report — or a credible, near-term path to one.
The company processed payment data for 300+ fintech apps. They had strong engineering. They did not have a compliance function.
Their options: hire a full-time security engineer (3–4 months to onboard and execute), engage a Big 4 firm (6-figure quote, 6-month timeline), or find a way to get audit-ready fast.
They found us.
The Challenge
Fintech API companies face a uniquely difficult compliance environment. They sit at the intersection of financial data and developer infrastructure — which means they inherit the security expectations of both industries. Every customer who integrates their API is implicitly trusting them with sensitive transaction data.
The specific challenges we inherited:
- Multi-cloud sprawl. Their infrastructure ran across AWS and GCP, with different logging configurations and access models on each platform. Neither was fully instrumented.
- API key management chaos. Production API keys were rotated manually and inconsistently. Some customers were running on keys that hadn't been rotated in 18 months. There was no automated rotation policy.
- Encryption gaps in transit. Certain internal service-to-service calls were running over HTTP in their GCP environment. This was a known technical debt item that had never been prioritized.
- No formal SDLC security gates. Developers pushed to production via a CI/CD pipeline, but there were no mandatory security scans, dependency audits, or code review requirements in the pipeline configuration.
- Incident response: undefined. They had PagerDuty set up for uptime alerts. They had no documented process for what to do when a security incident occurred.
The auditor they engaged (a specialized fintech-focused CPA firm) estimated 5 months to Type II certification through a standard engagement. We proposed a different model.
Our Approach
We embedded directly with their engineering team — two of our engineers working alongside their four — and ran a parallel-track sprint: infrastructure hardening on one track, documentation and policy on the other.
Days 1–2: Threat-Model-First Scoping
Rather than defaulting to a generic SOC 2 controls checklist, we started with a threat model specific to their business: a payment API handling high-value transactions. This let us prioritize the controls that mattered most for their actual risk surface — not just the ones auditors check off by default.
The output was a prioritized remediation backlog: 28 items, ranked by audit impact and implementation effort.
Days 3–9: Infrastructure Hardening
The multi-cloud environment required a coordinated approach:
AWS:
- Centralized CloudTrail into a dedicated security account with cross-account log aggregation
- Enabled AWS Config with rules for encryption compliance, public access settings, and IAM policy violations
- Tightened Security Groups — removed 7 overly permissive rules that allowed broad ingress
- Implemented automated API key rotation using AWS Secrets Manager with 90-day rotation schedules
GCP:
- Enabled Cloud Audit Logs across all services (Admin Activity + Data Access logs)
- Fixed all HTTP internal service calls — enforced mutual TLS across internal service mesh
- Deployed Cloud Security Command Center; resolved all HIGH-severity findings within the sprint window
SDLC:
- Added Snyk scanning to their GitHub Actions CI pipeline — mandatory pass required for production deploys
- Added Dependabot for automated dependency vulnerability alerts
- Formalized code review requirements: no single-author merges to main
Days 10–16: Policy, Process & Vendor Risk
We wrote 19 policies tailored to a fintech API context — not generic templates. Key documents:
- Incident Response Plan with a fintech-specific severity matrix (a P1 is different when you process live payments)
- Data Classification Policy — distinguishing between payment data, PII, API credentials, and internal operational data
- Cryptographic Standards Policy — documenting their encryption standards in transit and at rest, plus key management procedures
- Vendor Risk Assessment — evaluated their 11 critical vendors (payment processors, infrastructure providers, monitoring tools) against SOC 2 and ISO 27001 documentation
- Penetration Testing Policy — scheduled their first external pentest (a requirement the bank had specifically flagged)
Days 17–21: Evidence Package & Audit Prep
We collected 6 months of retrospective evidence where available (logs, access reviews, change records) and documented current-state controls with timestamped screenshots and configuration exports. We ran a mock audit interview with their CTO and Head of Engineering — prepping them for the auditor's questions on change management and access control processes.
Timeline
| Week | Focus | Key Deliverables | |------|-------|-----------------| | Week 1 | Threat modeling + multi-cloud hardening begins | Remediation backlog, AWS + GCP logging live | | Week 2 | SDLC gates + policy writing + vendor risk | 19 policies signed, Snyk + mTLS deployed | | Week 3 | Evidence collection + mock audit + handoff | Full evidence package, CTO audit prep complete |
Results
- ✅ SOC 2 Type II audit observation period began on Day 22 — a month ahead of their original projected start
- ✅ $2M bank contract signed within 60 days of audit report delivery
- ✅ Zero HIGH-severity findings in the Type II audit (2 low-severity informational findings, both documented with remediation notes)
- ✅ API key rotation automated — eliminated an entire category of credential exposure risk
- ✅ Internal HTTP calls eliminated — mTLS across all internal services
- 💰 Cost: ~60% less than the Big 4 quote they'd received; 4-month faster delivery
- 💰 ROI: Compliance sprint paid for itself 4x over in the first contract it unlocked
The bank's security team specifically called out their incident response documentation as "the most thorough we've seen from a company at this stage."
Key Learnings
1. Threat modeling beats generic checklists. A payment API has a different risk surface than a CRM SaaS. Starting with a threat model meant we spent time on what actually mattered — and didn't waste cycles on irrelevant controls.
2. Multi-cloud adds real complexity. Two cloud environments means two logging configurations, two access models, two sets of security tooling to instrument. If you're multi-cloud, budget extra time for the audit prep.
3. SDLC security gates are a forcing function. Adding Snyk to CI/CD didn't just satisfy an audit requirement — it immediately caught 3 high-severity vulnerabilities in their dependency tree that would otherwise have shipped to production.
4. Retrospective evidence matters. Auditors want to see that controls were in place during the observation period, not just that they exist now. If you have 6 months of logs, use them. If you don't, start the clock now.
5. Prepare your team for the audit interview. The auditor's questions aren't gotchas — but they're specific. Engineers who've never been audited can give technically correct answers in ways that create confusion. Mock interviews matter.
100x Engineering specializes in SOC 2 compliance sprints for fintech and API-first companies. Facing a compliance deadline? Let's talk about your timeline.