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ISO 27001 + PCI-DSS for mid-sized LATAM fintechs: the practical path

Nodier Solano 9 minMay 11, 2026

How not to burn 9 months and 200k USD. The real order of activities we see working — and which shortcuts are legitimate and which are not.

A mid-sized LATAM fintech facing ISO 27001 and PCI-DSS for the first time typically does it wrong — spends more, takes longer, and ends up with "paper" compliance that protects nothing. What follows is the order we see working with clients who certified at reasonable cost and time.

Step 0: scope before spending a peso

Audit scope determines cost. A fintech that throws its entire stack and every employee into scope will pay 3–5x what it would pay with scope properly limited to the cardholder data zone and the team operating it. Defining scope with an experienced consultant before starting saves months.

Step 1: honest gap assessment

Internal audit against the 93 ISO 27001:2022 controls and the 12 PCI DSS v4.0 requirements. Output: current compliance matrix + actions to close each gap. Effort estimate. Without this, you hire an external auditor and discover what is missing when it is too late.

Step 2: documentation people actually read

Security policy, access management policy, change management policy, incident response plan, vendor policy. The trap: buying templates online and filling them. The auditor sees it. Better: start from templates but adapt them to your real operation with real examples from your company.

Step 3: prioritized technical implementation

Encryption at-rest and in-transit (TLS 1.3, KMS), role-based access management, centralized logging with 12-month minimum retention, network segmentation, quarterly vulnerability scans, annual pen testing, patch management. Each one with an owner and a metric.

Step 4: internal audit before external

Before the external auditor, a formal internal audit by someone who did NOT operate the system (can be a consultant or a separate internal team). This surfaces gaps that slipped through. Cheaper than rescheduling the external auditor.

Step 5: external auditor and certification

Stage 1 (documentation) and Stage 2 (operation) for ISO. Annual RoC for PCI. Auditors with good LATAM track record: Deloitte, EY, BSI, Bureau Veritas, SGS — but also specialized regional firms that charge 30–50% less with similar quality for mid-sized companies.

What Colombia's Financial Superintendence watches in addition

ISO and PCI are not enough — the SFC requires SARO (Operational Risk Management System), specific ASOBANCARIA reports, and compliance with Circular Básica Jurídica for supervised entities. Bake this into scope from day one.

Legitimate shortcuts

AWS, Azure and GCP inherit hundreds of controls if you configure them per best practices. Using AWS Config + Security Hub with PCI conformance packs saves months of manual evidence. Native centralized audit logs. Not cheating — it is using the tools properly.

How we help at Athrun Data Intelligence

30-min call to review your situation and intended scope. If it fits, we support gap assessment, technical implementation and accompaniment all the way to the external audit.

Sources

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