U.S. AML Consulting Firm
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. Each engagement is scoped to the obligations that apply to your business model.
Before any engagement begins, we set out a written scope of work and clear deliverables. Typical starting points are preparing to register with FinCEN, answering a banking partner's compliance questions, or correcting findings from a prior review.
AML consulting services for U.S. regulated businesses
ComplyFactor is an AML consulting firm that works with U.S. Money Services Businesses, payment companies, and financial technology providers. Our U.S. practice is focused on BSA/AML, sanctions, and related compliance work.
Our AML consulting services cover three common needs: designing a BSA/AML program before you register, running an independent audit that a banking partner has asked for, and closing a gap that a state examiner flagged. Anti-money laundering consulting for MSBs, payment companies, and crypto platforms differs from consulting for a retail bank. The products, risk factors, and regulators are different, and a program built for one often does not fit the other.
Large enterprise consultancies are set up for bank-scale investigations and monitorships. ComplyFactor's AML compliance services are for money transmitters, remittance providers, certain payment businesses, and digital-asset companies that need compliance support without enterprise consulting overhead.
BSA/AML compliance services
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. 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.
Related reading: FinCEN MSB registration vs. state money transmitter licensing
What this means in practice
How our U.S. AML consultants can support your business
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BSA/AML Program Design and Enhancement
A written BSA/AML program built around your products, customers, and transaction flows: 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.
Independent BSA/AML Review
An independent review of whether your BSA/AML program works in practice. Our dedicated Independent BSA/AML Audit service covers scope, findings format, and review-frequency expectations in full.
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Fractional BSA/AML Officer Support
Senior BSA/AML officer coverage on a flexible basis, 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.
FinCEN MSB Registration
Support through FinCEN Form 107 registration: 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.
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State Money Transmitter Licensing
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. Federal FinCEN registration does not itself authorize money transmission in any state, and licensing is administered separately, state by state.
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AML Gap Assessments and Remediation
A structured review of an existing program against current FinCEN expectations, producing a written findings report with a prioritized remediation plan. Clients use it ahead of a banking partner review, after a change in business model, or as a standalone health check.
OFAC and Sanctions Compliance
Sanctions screening policies and procedures aligned to OFAC's requirements: list screening, blocked-transaction handling, and recordkeeping, all built into your broader BSA/AML program.
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Crypto and Digital Asset AML
BSA/AML program design for virtual currency exchangers, administrators, and other digital asset businesses, covering registration analysis, risk assessment, and the transaction-monitoring expectations that apply to virtual-currency activity.
Stablecoin & GENIUS Act Compliance
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. FinCEN and OFAC proposed the implementing rules in April 2026, and the rules are not yet final. We help issuers build a program against the requirements as they currently stand, and update it as the implementing rules are finalized.
Who we work with in the United States
Money Services Businesses & Money Transmitters
Currency dealers, check cashers, and money transmitters that are registered or registering with FinCEN, with state money transmitter licensing assessed separately where their activities require it.
Fintechs & Payment Companies
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.
Remittance Businesses
Cross-border money transfer providers managing agent networks and the AML obligations that come with high transaction volume.
Crypto & Digital Asset Businesses
Virtual currency exchangers and administrators building or strengthening the AML program that applies to their specific activity.
Stablecoin & Payment Infrastructure Businesses
Payment stablecoin issuers and infrastructure providers navigating the AML and sanctions compliance program requirements introduced under the GENIUS Act.
When businesses hire an AML consulting firm
U.S. AML regulations we help you navigate
Bank Secrecy Act (BSA)
The federal foundation for U.S. AML law. It sets program, registration, recordkeeping, and reporting requirements for financial institutions, including MSBs, calibrated to their specific activity and product type.
FinCEN
Administers the BSA, defines which business models qualify as MSBs, and sets national AML/CFT priorities that risk-based programs are expected to reflect.
Anti-Money Laundering Act of 2020
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.
OFAC
Sanctions screening and blocked-transaction obligations that sit alongside, and are increasingly integrated with, BSA/AML program requirements.
State money transmitter licensing
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. Federal registration does not itself authorize money transmission in any state.
What you receive from an AML consulting engagement
Why choose ComplyFactor for U.S. AML consulting?
Specialist AML/BSA practice
Our work centres on MSBs, payment companies, and digital-asset businesses.
BSA/AML officer coverage available
Fractional BSA/AML officer support can be added to an engagement where it is needed.
Written deliverables
Policies, risk assessments, and findings reports your team can act on.
Defined scope of work
A defined scope of work agreed before an engagement begins.
Cross-border regulatory perspective
The same practice also advises regulated businesses in Canada and other jurisdictions, useful for companies operating across multiple markets.
How an engagement works
Initial scoping call: free
We discuss your business model and regulatory situation.
Regulatory & business-model assessment
Confirming which FinCEN classification and state licensing requirements actually apply to you.
Written scope and deliverables
Set out in writing before work begins.
Specialist delivery
Our AML/BSA specialists carry out the work within the agreed scope.
Remediation or ongoing support
Where findings require follow-up work or continued advisory access.
U.S. AML consulting FAQs
An AML consulting firm helps a regulated business design, review, or strengthen its anti-money laundering program: 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 (such as money transmission or applicable prepaid-access activities), it may need to register with FinCEN and maintain a BSA/AML program suited 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, such as a program build, a licensing application, or 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, 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, 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.
Get your U.S. AML program scoped
FinCEN and state obligations differ from one business to the next. Book a scoping call and we'll assess your business model, confirm which requirements apply, and set out a written scope of work before any engagement begins.
