BSA/AML compliance consulting for fintechs, MSBs & payment companies across the United States.
ComplyFactor advises U.S. Money Services Businesses, payment companies, remittance providers, and digital asset platforms on Bank Secrecy Act and anti-money laundering compliance. Our work spans program design, independent reviews, FinCEN registration support, and fractional compliance officer coverage β scoped to the obligations that actually apply to your business model, not a template written for a bank.
Whether you're preparing to register with FinCEN, responding to a banking partner's compliance questions, or correcting findings from a prior review, we set out a written scope of work and clear deliverables before any engagement begins.
ComplyFactor is an AML consulting firm built specifically for U.S. Money Services Businesses, payment companies, and financial technology providers β not a generalist management consultancy that treats anti-money laundering as one line item among many.
Our AML consulting services cover the work a regulated business needs at every stage: designing a BSA/AML program before you register, running an independent audit a banking partner is asking for, or bringing in AML consultants to close a gap a state examiner flagged. Anti-money laundering consulting for MSBs, payment companies, and crypto platforms is genuinely different from AML consulting built for a retail bank β the products, the risk factors, and the regulatory relationships are not the same, and a program built for one rarely survives scrutiny in the other.
Where large enterprise consultancies are scoped for bank-scale investigations and monitorships, ComplyFactor's AML compliance services are designed for money transmitters, remittance providers, certain payment businesses, and digital-asset companies that need practical compliance support without enterprise consulting overhead.
The Bank Secrecy Act (BSA) is the foundation of U.S. anti-money laundering law. Covered MSBs must maintain an effective, written AML program, register with FinCEN where required, meet the customer identification and recordkeeping requirements that apply to their specific activity, and file the reports their business triggers. The exact obligations depend on MSB category, product, and transaction type β a check casher, a money transmitter, and a virtual currency exchanger are not covered in identical ways.
The Anti-Money Laundering Act of 2020 modernized the BSA framework, strengthened the focus on risk-based AML/CFT programs, and directed FinCEN to establish national AML/CFT priorities.
A written BSA/AML program built around your products, customers, and transaction flows β policies, procedures, a risk assessment, and a training framework. We build new programs for businesses preparing to register, and enhance existing programs that have outgrown their original scope.
An independent review of whether your BSA/AML program works in practice β not just whether the paperwork exists. Our dedicated Independent BSA/AML Audit service covers scope, findings format, and review-frequency expectations in full.
Senior BSA/AML officer coverage on a flexible basis β for businesses that need a designated compliance officer without the cost of a full-time senior hire, or that need experienced interim coverage during a transition.
Support through FinCEN Form 107 registration β determining whether your business model qualifies as an MSB, preparing the filing, and building the compliance program FinCEN expects to already be in place at the time you register.
Guidance on applicable state money transmitter licensing, assessed alongside your federal FinCEN obligations. Requirements depend on your specific activities and the states you operate in β federal FinCEN registration does not itself authorize money transmission in any state, and licensing is administered separately, state by state.
A structured review of an existing program against current FinCEN expectations, producing a written findings report with a prioritized remediation plan β used ahead of a banking partner review, after a change in business model, or as a standalone health check.
Sanctions screening policies and procedures aligned to OFAC's requirements β list screening, blocked-transaction handling, and recordkeeping built into your broader BSA/AML program rather than treated as a separate afterthought.
BSA/AML program design for virtual currency exchangers, administrators, and other digital asset businesses β covering registration analysis, risk assessment, and the transaction-monitoring expectations that apply to virtual-currency activity.
Support for payment stablecoin issuers navigating the AML and sanctions compliance program obligations introduced by the GENIUS Act. The Act itself requires permitted payment stablecoin issuers to maintain an AML and sanctions compliance program; the FinCEN/OFAC rules that will govern the supervisory detail were still being finalized at the time of writing. We help issuers build a program against the requirements as they currently stand, and update it as the implementing rules are finalized.
Currency dealers, check cashers, and money transmitters registered β or registering β with FinCEN, with state money transmitter licensing assessed separately where their activities require it.
Payment processors, card program managers, and financial technology providers whose products carry MSB-type obligations even when the company doesn't think of itself as one.
Cross-border money transfer providers managing agent networks and the AML obligations that come with high transaction volume.
Virtual currency exchangers and administrators building or strengthening the AML program that applies to their specific activity.
Payment stablecoin issuers and infrastructure providers navigating the AML and sanctions compliance program requirements introduced under the GENIUS Act.
The federal foundation for U.S. AML law β program, registration, recordkeeping, and reporting requirements for financial institutions, including MSBs, calibrated to their specific activity and product type.
Administers the BSA, defines which business models qualify as MSBs, and sets national AML/CFT priorities that risk-based programs are expected to reflect.
Modernized the BSA framework, strengthened the emphasis on risk-based AML/CFT compliance, and directed FinCEN to establish national AML/CFT priorities for financial institutions to consider in their compliance programs.
Sanctions screening and blocked-transaction obligations that sit alongside β and are increasingly integrated with β BSA/AML program requirements.
A separate framework from federal FinCEN registration. Businesses conducting money transmission may need a license in each state where they operate, depending on their activities β federal registration does not itself authorize money transmission in any state.
Focused on MSBs, payments, and digital-asset businesses β not banks, and not generalist management consulting.
In-house BSA/AML compliance officer expertise available to engagements.
Policies, risk assessments, and findings reports your team can act on.
A defined scope of work agreed before an engagement begins.
The same practice also advises regulated businesses in Canada and other jurisdictions, useful for companies operating across multiple markets.
We discuss your business model and regulatory situation.
Confirming which FinCEN classification and state licensing requirements actually apply to you.
Set out in writing before work begins.
Work carried out with appropriate AML/BSA compliance expertise based on the engagement scope.
Where findings require follow-up work or continued advisory access.
An AML consulting firm helps a regulated business design, review, or strengthen its anti-money laundering program β building policies and a risk assessment, running independent reviews, preparing for regulatory scrutiny, and supporting FinCEN registration or state licensing. The scope depends on where your business is in its compliance lifecycle.
Common triggers include preparing for FinCEN registration or applicable state money transmitter licensing, launching a new regulated product, replacing an outdated program, responding to a banking partner's compliance demands, or correcting findings from a prior review.
Many fintechs do, but not all. If a fintech's activities fall within one of FinCEN's Money Services Business categories β such as money transmission or applicable prepaid-access activities β it may need to register with FinCEN and maintain a BSA/AML program tailored to those activities. Classification depends on the actual services provided, how funds move through the business, and whether any regulatory exemption applies. Some payment-processing arrangements, for example, may fall outside money transmitter status when FinCEN's payment processor exemption is satisfied.
Most MSBs must register with FinCEN by filing FinCEN Form 107, generally within 180 days of the business being established, and renew that registration every two years. A narrow exception applies to persons who are MSBs solely because they act as an agent of another registered MSB.
An AML consultant provides guidance targeted at a specific need β a program build, a licensing application, remediation after a finding. An independent audit is a formal, structured assessment of whether your entire existing program works in practice, typically producing a written findings report. Businesses often need advisory work first to close known gaps, then an audit to confirm the fixes hold up.
Yes β this is one of our common engagements. A fractional officer provides senior BSA/AML compliance leadership on a flexible basis, which suits businesses that need a designated compliance officer without the cost of a full-time senior hire, or that need experienced coverage during a transition.
Often, yes β but it depends on the activity. Federal FinCEN registration and BSA/AML program obligations apply based on your MSB classification, and many states separately require a money transmitter license for businesses conducting money transmission within their borders. The two frameworks are administered separately and run on different timelines; federal registration does not itself authorize money transmission in any state.
Sanctions compliance and AML compliance are related but distinct obligations. In practice, most regulated businesses build OFAC screening and blocked-transaction procedures directly into their BSA/AML program rather than maintaining two disconnected frameworks.
Yes. We work with virtual currency exchangers and administrators on BSA/AML program design, and separately support payment stablecoin issuers navigating the AML and sanctions compliance program obligations introduced under the GENIUS Act.
Tell us your corporation's year-end, what the statements are for and the state of the records. You will receive a written scope and quote for financial statement preparation services matched to your business: preparation only, preparation with a compilation engagement, or statements coordinated with your T2 filing. Regulated businesses should not have to translate their own numbers for their provider.