Outsourced BSA Officer Support
We run the day-to-day work of your Bank Secrecy Act programme alongside your designated compliance officer: risk assessment, monitoring, reporting, training and examination readiness.
Outsourced BSA officer support means an experienced team runs the daily work of your anti-money laundering programme while your firm keeps the designated compliance person that 31 C.F.R. 1022.210 requires. We cover the risk assessment, alert review, SAR and CTR filing, agent oversight, training and examiner requests, monthly or while you hire.
Speak to a compliance expertSpeak 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
What we do
Every money services business must designate a person to assure day-to-day compliance with its anti-money laundering programme and the Bank Secrecy Act. Many money transmitters, especially in their first years of licensing or during fast growth, do not yet have a full in-house team with US Bank Secrecy Act experience, or need cover while they recruit.
We work as the team behind your designated officer. Your officer keeps the decisions and the sign-offs. We do the work and keep the evidence: the risk assessment, alert and case review, suspicious activity and currency transaction report preparation, sanctions screening hits, agent monitoring, training and the monthly reporting your board and partner banks expect to see. Read more about the [full yearly compliance cycle](/insights/money-transmitter-compliance-requirements-2026).
FinCEN proposed in April 2026 that the designated compliance officer of every financial institution be located in the United States and accessible to FinCEN. The proposal was not final at 27 October 2026. We help firms set up the role so that it meets that standard if it is adopted, and support the programme during the search for a permanent officer.
Programme baseline
We review the written programme, risk assessment, last independent review and open findings, and agree what must be fixed first.
Operating plan
A monthly calendar of work with owners, deadlines and the reporting your officer and board will receive.
Run the programme
Alert and case review, report preparation, screening hits, agent monitoring and training, documented as we go.
Report and prepare
Monthly management information, board reporting and evidence packs for examiners and partner banks.
What's Included
Risk assessment
A written assessment of products, customers, channels and geography, refreshed yearly and when the business changes.
Alert and case review
Transaction monitoring alerts reviewed, documented and escalated within your service levels.
SAR and CTR preparation
Suspicious activity reports drafted within 30 days of detection and currency transaction reports prepared within 15 days.
Agent oversight
Due diligence, training and monitoring of agents, with a yearly review schedule and recorded actions.
Training
Yearly and new-joiner training for staff and agents, with attendance and test records kept for examiners.
Examination and bank readiness
Evidence packs and draft responses for state examiners, the IRS and partner bank due diligence.
The monthly work, and who owns it
The designated officer stays accountable for the programme. This is how the work divides between us.
| Work | We do | Your designated officer |
|---|---|---|
| Risk assessment | Draft, refresh and map controls to each risk | Approves and presents to the board |
| Transaction monitoring alerts | Review, document and escalate | Decides on escalated cases |
| Suspicious activity reports | Draft the narrative and filing within 30 days of detection | Makes the filing decision |
| Currency transaction reports | Prepare and check within 15 days | Confirms |
| Sanctions screening hits | Investigate and record | Decides blocks and rejections |
| Agent oversight | Monitor agent transactions and run reviews | Approves action on agents |
| Training | Deliver and record | Confirms completion |
| Examiner and bank requests | Assemble evidence and draft responses | Signs the responses |
Who this service is for
Firm types
- - State-licensed money transmitters
- - Payment and remittance fintechs
- - Crypto and stablecoin firms registered as MSBs
- - Foreign payment groups entering the US market
Situations & Triggers
- - Newly licensed with no BSA team in place
- - Designated officer leaving or on extended leave
- - Examination or partner bank review announced
- - Fast growth in volumes, corridors or agents
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.
Related insights
Money Transmitter Compliance Requirements in 2026: The Full Yearly Cycle
Every federal and state compliance obligation for a licensed US money transmitter in one place: the BSA programme, reports, FinCEN registration, net worth, bonds, call reports, renewals and exams.
Money Transmitter Compliance Calendar: November 2026 to December 2027
Every recurring federal and state compliance date for US money transmitters from November 2026 to December 2027: renewals, call reports, Form 107, audited accounts and event-driven deadlines.
MSB Call Report: What Money Transmitters File Each Quarter Through NMLS
The MSB Call Report is due 45 days after each quarter end. Due dates for 2026 and 2027, the four sections, state-specific additions and the errors that lead to enforcement.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a compliance expertFrequently asked questions
The rule requires a money services business to designate a person to assure day-to-day compliance, and does not require that person to be an employee. Many firms use outside support to run the programme. Accountability stays with the firm and the person it designates, and under FinCEN's April 2026 proposal that person would need to be located in the United States.
Risk assessment, transaction monitoring alert review, suspicious activity and currency transaction report preparation, sanctions screening hits, agent oversight, training, monthly management information, board reporting and support with examiner and partner bank requests.
Not under the rule in force today. FinCEN's proposed AML/CFT programme rule of April 2026 would require the designated officer to be located in the United States and accessible to FinCEN. As at 27 October 2026 the proposal had not been finalised.
We prepare the narrative and the filing. The decision to file stays with your designated officer, and the report is filed through your own FinCEN BSA E-Filing account within 30 days of initial detection.
Support runs the programme; an independent review tests it. The reviewer cannot be the person who runs the programme or anyone reporting to them, so we do not review a programme we support. We will tell you when a different reviewer is needed.
Yes. We support virtual currency businesses registered as MSBs, including blockchain analytics alerts, travel rule data for transfers of USD 3,000 and above, and preparation for the GENIUS Act, which takes effect on 18 January 2027.
With a baseline review of the written programme, the risk assessment, the last independent review and any open findings. We then agree a monthly plan, the reporting your officer will receive and the first fixes.
As a fixed monthly retainer scoped to your volumes, products, states and agents. The scope and the fee are set out in writing before work begins.