PNYX HILL GRC ADVISORS
Regulatory Strategy and Advisory
We advise boards, executives, founders and investors on the regulatory decisions that determine how a financial-services institution can establish, operate, expand or transact across Europe. Mandates address regulatory perimeter, home jurisdiction, authorisation strategy, ownership, capital, governance, cross-border rights and supervisory approach.
From our offices in Nicosia and Athens, we connect the European rulebook with local supervisory practice in Cyprus, Greece and the wider EU. We test the intended business model against the applicable requirements and establish a defensible regulatory position that can be carried through authorisation, implementation and ongoing supervision.
When Clients Engage Us
Clients engage us when growth has slowed and the underlying cause is unclear; when a new market, business or investment requires a rigorous strategic case; when capital and management attention must be reallocated; or when the current strategy no longer reflects the realities of the market.
We are also engaged when structural, technological or regulatory change has challenged the assumptions behind the strategy; when performance has diverged materially from the strategic plan; when a change in ownership or leadership requires the organisation’s direction to be reset; or when a board needs independent challenge before making a consequential and difficult-to-reverse decision.
Regulatory Perimeter and Activity Classification
We determine which regulated activities, instruments, products and customer relationships arise from the proposed model. The analysis follows what the institution will do in practice, including how services are marketed, contracted, delivered and remunerated.
Where several regimes may apply, we map the boundaries and dependencies between investment services, crypto-assets, payments, electronic money, fund management, credit and banking. This establishes the permissions, restrictions and specialist opinions required before the model advances.
Our work covers:
Activity, instrument, product, client and distribution-channel mapping
MiFID II, MiCA, AIFMD, UCITS, payments and banking perimeter analysis
Regulated, exempt, ancillary and out-of-scope activity assessment
Financial-instrument, crypto-asset, payment and token classification
Cross-border marketing, solicitation and service-delivery analysis
Regulatory perimeter paper, assumptions register and decision record
EU Home-Jurisdiction Selection and Regulatory Structuring
We compare potential EU home jurisdictions against the institution’s activities, target markets, ownership, capital, management substance and operating requirements. Cyprus and Greece are assessed through our local presence; other EU routes are evaluated and coordinated with jurisdiction-specific advisers where required.
We then define the regulated entity, branch, passporting and group structure needed to support the selected route. The work distinguishes activities that can be passported from those requiring a host-state notification, branch, local establishment or additional authorisation.
Our work covers:
Cyprus, Greece and wider-EU jurisdiction comparison
Home-state, host-state and NCA assessment
Subsidiary, branch, passport and cross-border service options
Ownership, control, substance and local-presence requirements
Group structure, delegation, outsourcing and shared-service implications
Jurisdiction recommendation and implementation sequence
Regulatory Business Model and Operating Strategy
We test whether the institution’s commercial and revenue model can operate within the intended permissions and regulatory conditions. The assessment covers clients, products, transaction flows, fees, assets, distribution, outsourcing, technology and intra-group services.
The agreed position is translated into decisions on regulated functions, governance, capital, local substance, systems, controls and resourcing. This keeps the licence strategy, financial model and operating model aligned around the same assumptions.
Our work covers:
Business-model, revenue-stream and transaction-flow assessment
Client, product, service and distribution architecture
Permission, restriction and licence-condition analysis
Regulated-function, delegation and outsourcing design
Capital, prudential, governance and substance implications
Regulatory operating model and implementation priorities
New Products, Digital Assets and Innovation Advisory
We assess new products, activities and technology-enabled propositions before development or launch commitments become difficult to reverse. The work establishes regulatory classification, permission requirements, customer and conduct implications, control expectations and the appropriate engagement pathway.
Mandates may involve crypto-assets, tokenisation, payments, embedded finance, investment products, digital distribution and new delivery models. Where a proposition crosses regulatory boundaries, we determine the lead regime and coordinate any legal or technical opinions required from appropriately qualified specialists.
Our work covers:
New-product and regulated-activity assessments
MiCA, MiFID II, payment and tokenisation perimeter analysis
Crypto-asset, financial-instrument and payment-token classification
Product governance, customer, conduct and disclosure implications
Technology, custody, data, outsourcing and Digital Operational Resilience Act (DORA) considerations
Regulatory engagement and implementation roadmap
EU Regulatory Change and Impact Assessment
We assess European and national regulatory developments and determine their effect on the institution’s permissions, governance, products, capital, controls and operating model. The analysis separates binding requirements, implementation deadlines and supervisory expectations from matters still under legislative development.
We convert the assessment into accountable workstreams, policy and control changes, evidence requirements and implementation milestones. Current mandates may address DORA, MiCA, AIFMD II implementation, the evolving EU AML framework and readiness for PSD3 and PSR.
Our work covers:
EU and national regulatory horizon scanning
Applicability, gap and business-impact assessment
Product, capital, governance and operating-model implications
Policy, process, system and control requirements
Board decision papers and implementation roadmaps
Multi-jurisdiction change coordination and readiness reviews
Regulatory Due Diligence and Transaction Advisory
We advise acquirers, sellers, shareholders and regulated institutions on the regulatory position of proposed acquisitions, disposals and restructurings. The work identifies permission constraints, qualifying-holding and change-in-control requirements, supervisory matters and control deficiencies that may affect timing, conditions, value or execution.
We also assess licence continuity and the post-completion governance, regulated functions, remediation and operating-model changes required. Our work does not include investment advice, transaction brokerage, legal opinions, valuations or other reserved services.
Our work covers:
Regulatory due diligence for regulated-business transactions
Licence, permission and regulatory-history assessment
Supervisory findings, remediation and enforcement review
Qualifying-holding and change-in-control requirements
Regulatory conditions, dependencies and execution risks
Post-completion governance and regulatory integration roadmap
Related services: M&A Strategy and Transaction Readiness; Licensing and Regulatory Authorisations
Regulatory Engagement and Supervisory Strategy
We prepare boards and senior management for material engagement with NCAs, from initial business-model discussions and authorisation meetings to supervisory reviews and remediation programmes. We establish the institution’s position, supporting evidence, decision authority and communication approach.
The objective is a consistent regulatory narrative supported by operational facts. We coordinate meeting preparation, submissions, information requests and commitments while preserving clear ownership and formal accountability within the institution.
Our work covers:
Pre-application and material-change engagement strategy
Regulatory position papers and decision materials
Board, executive and key-person meeting preparation
Supervisory review and information-request coordination
Response strategy for findings and remediation commitments
Regulatory communications, evidence and commitment tracking
