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A senior compliance officer who runs your BSA/AML programme, state licence obligations, examinations and partner bank relationships as a member of your leadership team.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Every US money transmitter licence and every FinCEN MSB registration requires a designated compliance officer: an individual accountable for the BSA/AML programme, with the authority, independence and experience that state examiners and partner banks test.
We provide that officer. A senior BCC compliance professional serves as your Chief Compliance Officer and BSA Officer, sits on your leadership team, runs monitoring and investigations, files your reports, leads every examination and reports to your board. The appointment can run for as long as you need it, or until you appoint a permanent officer, with a full handover.
Ownership of the written programme, risk assessment, customer due diligence, transaction monitoring, sanctions screening and suspicious activity reporting.
Call reports, annual renewals, change notices, surety bond and net worth monitoring, and filings through NMLS for every state you hold.
The single point of contact for state examiners, the independent testing firm and partner bank due diligence, with findings tracked to closure.
Board reporting on compliance, annual staff training and the record keeping each regulator expects.
| Deliverable | What it contains | Who relies on it |
|---|---|---|
| Chief Compliance Officer and BSA Officer | A senior officer running the BSA/AML programme day to day | State regulators, FinCEN, partner banks |
| Programme and risk assessment | Written BSA/AML programme and enterprise risk assessment kept current | Examiners, independent testers |
| Compliance calendar | Every state and federal filing, renewal and deadline, owned and tracked | Board, state regulators |
| Board reporting | Monthly compliance report covering monitoring, filings, findings and changes in the rules | Board, investors |
| Examination file | Evidence, responses and remediation for each examination and independent test | State examiners, partner banks |
Every money services business registered with FinCEN must designate a person responsible for day-to-day BSA/AML compliance, and state money transmitter regulators review that person's experience at licensing and at every examination. Stablecoin issuers and crypto firms holding money transmitter licences are held to the same standard.
Yes. Regulators look at the individual's experience, authority, independence and access to the board, not at the employment contract. The appointment is documented in the programme and the board approval, and the officer works inside the firm's systems and reporting lines.
The test is whether the officer is qualified, accountable and effective. We prepare the evidence examiners and bank due diligence teams ask for: the appointment, the officer's experience, the reporting lines and the record of the work done.
Yes. Many states assess the proposed compliance officer as part of the application, so the officer can be appointed before submission and stay in place after the licence is granted.
Yes. When you appoint a permanent officer we run a structured handover of the programme, the calendar, open findings and regulator correspondence.
Tell us what you need and where you operate.