For money transmitters and MSBs
Every state examines you. Be ready for all of them.
A money transmitter answers to FinCEN and to each state that licenses it. We help you get licensed, run the AML program those examiners read, and keep the evidence ready for the next exam.
Your problem
One program, many examiners, and an agent network you don't run
- Each state license comes with its own application, its own deficiency letters and its own exam cycle.
- Your AML program has to meet 31 CFR 1022.210 and hold up to every state examiner who reads it.
- Your agents deal with your customers, and their compliance failures become yours.
- Screening and monitoring alerts pile up, and a SAR decision that isn't documented won't hold up at exam.
- Your compliance team is small, and an exam or a new license application takes it off everything else.
The work, by the obligation it answers
- State licensing
Licensing and deficiency responses
Applications prepared, deficiency letters answered, and FinCEN registration under 31 CFR 1022.380 kept current.
- The base of your AML program
BSA/AML risk assessment
Your products, customers, geographies and agents assessed, so the program matches the risk it's built for.
- Your independent review
BSA/AML independent testing
Every record in scope tested, with work papers, findings cited to their rule, and a signed report.
- Sanctions screening
Sanctions screening
Lists from the issuing authorities, and the evidence behind each match decision.
- Transaction monitoring
Transaction monitoring
Monitoring across your customers and agents, with each alert, its disposition and its reviewer on the record.
- Monitoring that holds up
Transaction monitoring validation
Rules, thresholds and data feeds checked against your risk assessment.
- Alerts, cases and SARs
Managed compliance operations
Alert review, case work and SAR preparation by our team. You review each SAR and file it with FinCEN.
- Agent oversight
Automated control testing
Every agent's transactions tested against the controls you require of them, with the results by agent.
- Exam findings
Remediation and issue management
Exam and audit findings turned into a sequenced plan and tracked to evidenced closure.
Exam readiness
The same evidence for every state that asks
State examiners ask for the same core record: the risk assessment, the policies, the independent review, training, monitoring and screening results, SAR decisions and agent oversight. We keep that record in one place, so answering a second state's request doesn't mean starting over.
If you need a compliance officer, or yours is stretched, we provide a fractional compliance officer who owns the program with you.
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Practitioner guides
How the work is done
The audit you already buy, performed by an engine.
- Every record testedControls are tested against the full population of accounts and transactions, not a sample of twenty-five.
- Every requirement citedEach requirement the work runs against is cited to the rule it comes from, with the facts behind it labelled.
- Findings pricedFindings arrive priced in dollars, so remediation is ordered by what each gap is worth.
- A signed reportThe report is signed, and any reader can check that nothing in it changed after signing.
Talk to a practitioner
Book a 15-minute chat with our founder.
A real conversation with a senior compliance leader, to see if there's a fit. Not a sales call, not a demo, no pressure.