Fractional BSA/AML Officer Services
ComplyFactor provides fractional BSA/AML officer services for U.S. Money Services Businesses, money transmitters, remittance companies, and payment businesses. A BSA officer is the person an MSB designates under 31 CFR § 1022.210(d)(2) to oversee day-to-day compliance with its AML program and the Bank Secrecy Act. ComplyFactor provides specialist support around that function on a flexible basis.
This is ongoing compliance support, not a periodic check — distinct from the independent testing an outside reviewer performs separately.
31 CFR § 1022.210(d)(2)
Every MSB must designate a person to assure day-to-day compliance with its AML program and the Bank Secrecy Act. The regulation names a responsibility, not a job title or a specific employment arrangement.
How ComplyFactor Supports U.S. MSBs With BSA/AML Compliance
ComplyFactor provides fractional or outsourced BSA/AML officer support: senior compliance expertise on a flexible basis, rather than hiring a full-time, in-house officer immediately. Our support sits between handling compliance entirely in-house and bringing in specialist help around the day-to-day compliance function. This suits businesses that need experienced input into an AML program but don't yet have the transaction volume, product complexity, or budget to justify a dedicated senior hire — as well as businesses mid-transition, such as after an officer's departure or during a period of rapid growth.
Who this is for
What Does a BSA Officer Do?
A BSA officer — the term MSBs use for the person designated under 31 CFR § 1022.210(d)(2) — is responsible for day-to-day compliance with a business's AML program and the Bank Secrecy Act. In practice, that typically includes keeping policies and procedures current, overseeing monitoring and escalation, helping ensure applicable reports and records are filed and retained correctly, coordinating training, maintaining the risk assessment, tracking remediation of known issues, and reporting compliance status to management. The exact scope depends on the business's size, products, and risk profile — a check casher's BSA officer and a multi-corridor remittance business's BSA officer aren't doing identical jobs.
MSB Compliance Officer Requirements
31 CFR § 1022.210(d)(2) requires every MSB to designate a person to assure day-to-day compliance with its AML program and the Bank Secrecy Act. The responsibilities that must attach to that person include helping ensure reports and records are properly filed and retained, that the program is kept current, and that required training is provided. The regulation names a responsibility, not a job title or a specific employment arrangement — it doesn't specify that the designated person must be a full-time employee.
FinCEN's MSB examination materials direct examiners to assess the designated individual's actual knowledge of BSA/AML requirements as part of an examination — not simply confirm that a designation has been made on paper. Outsourcing the role changes who performs the work; it doesn't change the MSB's own responsibility for maintaining an effective AML program.
Where an MSB needs experienced support around these responsibilities, ComplyFactor can help define and support the compliance function based on the business's structure and risk profile.
Regulation vs. examination practice
What Our Fractional BSA/AML Officer Support Can Include
Scope is agreed during onboarding and reflects your size, products, and risk profile.
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Program Support
Our team supports day-to-day elements of the AML program, including keeping policies and procedures current.
Regulatory Reporting Support
Support extends to applicable reporting and recordkeeping processes, where included in the agreed scope.
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Risk Assessment & Updates
We help keep the risk assessment aligned with changes in products, corridors, volume and risk.
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Training & Internal Coordination
Our team coordinates training delivery and works with your internal teams and management.
Bank & Examination Support
Support for banking-partner due diligence, examination readiness, and remediation tracking, where scoped.
When a Fractional BSA Officer Makes Sense
These are situations in which an MSB may seek fractional support around its compliance-officer function — not requirements in themselves; the requirement is the designation itself.
Newly Registered / Early-Stage
An MSB that needs experienced input before it can justify a full-time hire.
Rapid Growth
Growth that has outpaced the original compliance setup.
Officer Transition
A transition period after a BSA officer's departure.
Banking & Examination Scrutiny
Increasing banking-partner scrutiny or an upcoming examination.
Remediation
Working through remediation following prior findings.
If one of these situations reflects where your business is today, we can scope the level of BSA/AML support your existing team actually needs.
How We Deliver Fractional BSA/AML Officer Support
Scoping
Understanding your business model, products and current compliance setup.
Program & Business Review
We review the current AML program and identify where senior support is needed.
Responsibilities Agreed
We document the agreed scope, responsibilities and boundaries of the engagement.
Operating Cadence
Regular touchpoints for support, escalation and reporting.
Management Reporting
Structured updates to management on the agreed cadence.
Review of Priorities
We revisit priorities as the business and risk profile change.
Fractional BSA Officer vs Full-Time Hire
Fractional / Outsourced BSA Officer
Full-Time Internal Officer
Most money transmitters need both — federal registration doesn't substitute for a missing state license, and a state license doesn't remove the federal registration requirement.
BSA/AML Officer Support vs Independent BSA/AML Audit
These are different functions. A BSA/AML officer carries ongoing, day-to-day responsibility for your compliance program. An independent BSA/AML audit is a periodic, independent assessment of whether that program works — and under 31 CFR § 1022.210(d)(4), the person conducting that review can't be the same person designated as your day-to-day compliance officer.
Looking for broader AML consulting?
Why Work With ComplyFactor for Fractional BSA/AML Support
Specialist AML/BSA Focus
Not a generalist consultancy — AML/BSA is the whole practice.
MSB & Payment-Sector Familiarity
Remittance, money transmission, and payments experience shapes how support is scoped.
Flexible Senior Support
Capacity that scales with your business, not a fixed package.
Practical Coordination
Working with your management team, not just producing a written report.
FAQs
The regulation requires a designation, not a specific employment type, so outsourcing the role isn't categorically prohibited. FinCEN's MSB examination materials direct examiners to assess the designated individual's actual knowledge of BSA/AML requirements — not simply confirm a title exists. Outsourcing changes who performs the work; it doesn't change the MSB's own responsibility for the program.
No. 31 CFR § 1022.210(d)(2) requires a designation, not a specific employment arrangement, and doesn't specify that the person must work full time or be an employee at all. What matters is that the designated person can actually carry out the responsibilities the regulation attaches to the role — filing and retaining required reports and records, keeping the program current, and ensuring training is provided.
31 CFR § 1022.210(d)(2) doesn't itself specify a required level of authority or resources — that level of detail is more associated with bank-specific examination standards than MSB rules. As a practical matter, the designated person needs enough standing and access within the business to actually perform the responsibilities the regulation assigns: ensuring reports and records are handled correctly, keeping the program updated, and making sure training happens.
In the U.S. MSB context, the terms are generally used interchangeably to describe the same designated role under 31 CFR § 1022.210(d)(2). Other jurisdictions use different titles for a broadly similar function — for example, "MLRO" in the UK — but that role sits under different rules and isn't identical to the U.S. BSA officer function.
Yes — fractional support is often used to supplement an existing team rather than replace it, for example providing senior-level input, covering a gap, or supporting a specific project such as an upcoming review. The specific working arrangement, including who holds the formal designation, is agreed during scoping.
Typically an overview of your business model and products or services, your current AML program and compliance structure, any known issues or prior findings, and the scope of support you're looking for. The exact engagement details are confirmed during scoping.
Discuss Your BSA/AML Officer Needs With Our Team
Tell us about your business model, current compliance structure, and the support you're looking for — we'll confirm the appropriate scope before anything begins.
