US MONEY TRANSMITTER COMPLIANCE

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 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 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.

01

Programme baseline

We review the written programme, risk assessment, last independent review and open findings, and agree what must be fixed first.

02

Operating plan

A monthly calendar of work with owners, deadlines and the reporting your officer and board will receive.

03

Run the programme

Alert and case review, report preparation, screening hits, agent monitoring and training, documented as we go.

04

Report and prepare

Monthly management information, board reporting and evidence packs for examiners and partner banks.

DELIVERABLES

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.

WorkWe doYour designated officer
Risk assessmentDraft, refresh and map controls to each riskApproves and presents to the board
Transaction monitoring alertsReview, document and escalateDecides on escalated cases
Suspicious activity reportsDraft the narrative and filing within 30 days of detectionMakes the filing decision
Currency transaction reportsPrepare and check within 15 daysConfirms
Sanctions screening hitsInvestigate and recordDecides blocks and rejections
Agent oversightMonitor agent transactions and run reviewsApproves action on agents
TrainingDeliver and recordConfirms completion
Examiner and bank requestsAssemble evidence and draft responsesSigns the responses
WHO WE WORK WITH

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 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

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.