US MONEY TRANSMITTER COMPLIANCE

Independent AML Testing

Independent reviews of anti-money laundering programmes for money transmitters, money services businesses and payment fintechs, built for examiners and partner banks to rely on.

An independent AML review tests whether a money services business's anti-money laundering programme works, as 31 C.F.R. 1022.210 requires. We test every element (risk assessment, controls, reporting, record keeping, training and the compliance officer's work) on samples of real transactions, and deliver a rated findings report with agreed corrective actions.

Speak to a compliance expert

Speak to a compliance expert

Tell us the business, the states you hold licences in and where your programme stands. Every enquiry is answered the same business day, with a written proposal setting out the scope, the team and the timing.

Your enquiry

Every enquiry is answered the same business day, with a written proposal.

HOW WE CAN HELP

What we do

Every money services business must have its anti-money laundering programme independently reviewed, with scope and frequency matched to its risk. FinCEN's guidance allows an employee to do it, but never the designated compliance person or anyone who reports to them. Examiners and partner banks ask for the latest review, and the firm's response to it, before almost anything else.

Our reviews test operation, not only documents. We take samples of customer files, transactions, alerts, suspicious activity and currency transaction reports, screening hits, agent files and training records, and test them against your written programme and the rules. Each finding is rated, traced to its cause and agreed with management, with an owner and a date. We return to test that the fixes work. See [what examiners check across the year](/insights/money-transmitter-compliance-requirements-2026).

We do not test a programme we help to run. If we provide [BSA programme support](/services/outsourced-bsa-officer) to your firm, we will tell you to appoint a different reviewer.

01

Scoping

We read the risk assessment and agree products, states, agents, period covered and sample sizes, set out in a scoping memo.

02

Fieldwork

Document review, interviews with the compliance officer and staff, and testing of transactions, alerts and reports.

03

Findings

Each finding rated by severity with its root cause, discussed with management before the report is final.

04

Report and follow-up

A final report for the board, examiners and partner banks, then follow-up testing of corrective actions.

DELIVERABLES

What's Included

Scoping memo

The areas, period, sample sizes and timetable, agreed before fieldwork starts.

Programme review

The written programme and risk assessment tested against the rules and against how the business really operates.

Transaction and alert testing

Samples of customers, transfers and alerts traced from start to finish.

Reporting test

Suspicious activity and currency transaction reports checked for quality, aggregation and timeliness.

Rated findings report

Findings by severity, with root causes, management responses, owners and dates.

Follow-up testing

Corrective actions re-tested and closed, with evidence for the next examination.

What the review covers

Scope follows FinCEN's guidance on independent reviews (FIN-2006-G012) and is set by your risk assessment.

AreaWhat we testEvidence examined
Risk assessmentIt reflects current products, customers, channels and geographyRisk assessment, product list, volumes by corridor
Customer identification and due diligenceRecords meet the policy and the rulesSample of customer files
Transaction monitoringRules fit the risks and alerts are reviewed on timeRule list, alert sample, case files
Suspicious activity reportsDecisions are reasoned and reports filed within 30 daysReport files and no-file decisions
Currency transaction reportsAggregation is correct and reports filed within 15 daysReport sample and cash records
Funds transfersRequired details collected and passed on from USD 3,000Transfer sample
Sanctions screeningLists are current and hits resolved and recordedScreening set-up and hit sample
AgentsDue diligence, training and monitoring of agentsAgent files and agent transaction monitoring
TrainingDelivered, current and suited to each roleTraining records and materials
Compliance officerAuthority, resources and actions takenReports, minutes and escalation records
Previous findingsCorrective actions completed and effectiveLast review and action tracker
WHO WE WORK WITH

Who this service is for

Firm types

  • - State-licensed money transmitters
  • - Payment fintechs operating as MSBs
  • - Crypto and virtual currency businesses
  • - Cheque cashers, currency dealers and prepaid access providers

Situations & Triggers

  • - Yearly review due
  • - State or IRS examination announced
  • - Partner bank due diligence request
  • - New product, corridor or acquisition, or an enforcement order requiring reviews
WHY REGULATORY COUNSEL

Why firms choose Regulatory Counsel

200+ licence and registration engagements

Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.

Senior-led

The same senior practitioners run your engagement from the first assessment to the last regulator question.

Every regulated sector

Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.

In writing, the same day

Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.

Ready to get started?

Every enquiry is answered the same business day, with a written proposal.

Speak to a compliance expert

Frequently asked questions

Yes. 31 C.F.R. 1022.210(d)(4) requires every money services business to provide for independent review of its anti-money laundering programme, with scope and frequency matched to the risk of its services.

Federal rules set no fixed interval. FinCEN's guidance says frequency should follow the risk assessment, and a review may need to come sooner after problems are found. Most state regulators and partner banks expect one every year, and enforcement orders commonly require it yearly.

An employee or an outside firm, but not the designated compliance person or anyone who reports to them. FinCEN's guidance says a money services business does not necessarily need an outside auditor or consultant.

Every element of the programme: policies, procedures and internal controls, the risk assessment, reporting and record keeping, sanctions screening, agent oversight, training and the actions of the compliance officer, tested on real samples.

It depends on the number of products, states, agents and transactions in scope. We set the timetable in the scoping memo before fieldwork starts, and plan it so that findings can be closed before the NMLS renewal window.

They ask for the latest review and the firm's response to it. A review backed by sample testing, rated findings and documented work papers carries more weight than a review of documents alone.

Yes. For virtual currency businesses we also test blockchain analytics alerts, wallet screening, travel rule data and how the risk assessment treats each asset and network.

Management records a response, an owner and a date for each finding. We return to test the corrective actions and confirm in writing when each is closed.