AML, BSA and Financial Crime programs for fintechs, banks, and digital asset firms

Anti-money laundering and Bank Secrecy Act compliance is no longer a back-office function. It is a board-level obligation, a sponsor bank requirement, and a condition of every financial partnership your organization enters. Equinox Compliance builds, manages, and strengthens AML programs that are risk-based, data-driven, and designed to meet the expectations of FinCEN, federal and state regulators, auditors, and bank partners. Our team brings deep experience across fintech, banking, BaaS, payments, lending, and digital assets.

The landscape for AML and financial crime compliance has shifted. Regulators expect programs that go beyond basic policies and checklists. They evaluate whether your risk assessment drives real decisions, whether your transaction monitoring rules reflect actual product behavior, whether suspicious activity investigations are thorough and timely, and whether governance keeps pace with growth.

For fintechs and BaaS platforms, sponsor banks now require detailed AML documentation, independent testing results, and ongoing reporting as conditions of the relationship. For banks, the scope of BSA obligations has expanded to include oversight of every fintech partner, every product channel, and every customer segment operating under the charter.

Digital asset firms face additional complexity. Evolving FinCEN guidance, state-level requirements, and increasing enforcement scrutiny mean that AML programs for crypto must be purpose-built, not adapted from legacy banking templates. Across every sector, the standard is the same: your AML program must be current, risk-aligned, and demonstrably effective.

We build complete AML and BSA programs from the ground up or redesign existing programs that no longer meet regulatory or sponsor bank expectations. Every program we deliver is structured around FinCEN requirements, the FFIEC BSA/AML Examination Manual, and applicable state guidance.

• Design program governance including BSA Officer designation, committee structures, and Board reporting
• Establish AML policies, procedures, and internal controls tailored to your products, customer base, and risk profile
• Map program components to specific regulatory obligations across BSA, USA PATRIOT Act, and FinCEN guidance
• Deliver a phased implementation plan that prioritizes highest-risk areas first

We conduct comprehensive AML and BSA risk assessments that serve as the foundation for every program decision, from customer due diligence thresholds to transaction monitoring rule design.

• Perform enterprise-wide and product-level AML risk assessments aligned with FFIEC methodology
• Evaluate customer, geographic, product, and channel risk across all business lines
• Identify gaps between current controls and risk exposure
• Deliver risk-rated findings with actionable remediation recommendations that satisfy regulators and auditors

We design CDD and EDD frameworks that meet regulatory expectations while remaining operationally realistic for the teams implementing them.

• Build CIP, CDD, and EDD workflows aligned with FinCEN Customer Due Diligence Rule requirements
• Define risk-based thresholds for enhanced review, ongoing monitoring, and periodic refresh
• Design beneficial ownership identification and verification processes
• Establish procedures for PEP screening, adverse media review, and high-risk customer management

We design transaction monitoring programs and SAR processes that produce defensible outcomes, not just alerts.

• Design risk-based transaction monitoring rules and scenarios tailored to your product and customer behavior
• Build alert investigation workflows with documented decision criteria and escalation paths
• Establish SAR preparation, review, and filing processes that meet FinCEN quality and timeliness expectations
• Support rule tuning, threshold optimization, and back-testing to reduce false positives and close detection gaps

We build sanctions compliance frameworks that cover OFAC obligations and integrate cleanly into onboarding, transaction processing, and ongoing monitoring.

• Design OFAC and sanctions screening programs for customers, counterparties, and transactions
• Establish screening cadence, hit disposition workflows, and escalation protocols
• Build processes for managing true matches, potential matches, and interdiction requirements
• Support implementation and configuration of screening technology and vendor solutions

We conduct independent testing of AML programs and support organizations preparing for BSA audits, regulatory exams, and sponsor bank reviews.

• Perform independent testing across all BSA/AML program components per FFIEC standards
• Develop risk-based test plans with defined scope, sampling methodology, and reporting
• Prepare audit-ready documentation packages including findings, recommendations, and management responses
• Support remediation planning and tracking for audit and exam findings

We manage the recurring deliverables that keep your AML program current, compliant, and exam-ready year over year.

• Conduct annual AML and BSA risk assessments with documented methodology and findings
• Manage annual independent testing and program effectiveness reviews
• Prepare Board and committee reporting packages on AML program performance
• Coordinate regulatory change management to keep your program aligned with new FinCEN rules, OFAC updates, and enforcement trends

1. Discovery and Risk Assessment — We evaluate your current AML program maturity, map your products and customer segments against BSA risk categories, and identify gaps in governance, controls, monitoring, and reporting.
2. Program Design — We design an AML and BSA framework tailored to your business model, risk profile, partner requirements, and team capacity. This covers governance, policies, CDD/EDD, monitoring, SAR processes, sanctions, training, and reporting.
3. Implementation — We build and deliver each program component in a phased rollout, working alongside your compliance, operations, and technology teams to ensure adoption and operational fit.
4. Ongoing Support — We manage annual deliverables including risk assessments, independent testing, Board reporting, rule tuning, and regulatory change management so your program stays current and defensible.

AML practitioners, not generalists. Our team includes professionals who have built and managed AML programs at banks, fintechs, crypto platforms, and financial technology firms. We design programs based on what works in practice, not theoretical frameworks.

Risk-based and data-driven. We build AML programs anchored in risk assessment methodology and actual transaction data. Every monitoring rule, CDD threshold, and testing plan is tied back to your specific risk profile.

Cross-sector depth. We operate across fintech, banking, BaaS, payments, lending, and digital assets. This means your AML program reflects the specific regulatory landscape, product behaviors, and shared control dynamics of your business model.

Full lifecycle ownership. We do not hand off a program and walk away. We manage annual risk assessments, independent testing, rule tuning, Board reporting, and program enhancements so your AML program stays effective as your business evolves.

Examination and sponsor bank credibility. Our work is designed to satisfy FinCEN, FDIC, OCC, state regulators, independent auditors, and sponsor banks. We understand what BSA examiners evaluate because our team has operated on both sides of the table.

• Fintechs building an AML program for the first time ahead of a sponsor bank onboarding or state licensing requirement
• Banks and credit unions strengthening BSA programs to meet heightened regulatory expectations
• BaaS platforms and sponsor banks designing scalable AML oversight frameworks for fintech partners
• Crypto and digital asset firms establishing AML programs aligned with evolving FinCEN guidance and state requirements
• Payments companies, PayFacs, and processors building or upgrading AML infrastructure during growth
• Organizations responding to BSA exam findings, MRAs, consent orders, or enforcement actions requiring program remediation
• Companies preparing for independent BSA audits, regulatory exams, or sponsor bank reviews

• Compliance Management Systems — Design and manage the full CMS framework that houses your AML program alongside governance, testing, training, and issue management
• Risk Assessments — Conduct enterprise-wide and product-level risk assessments that feed directly into AML program design and monitoring strategy
• Audit and Examination Readiness — Prepare your team and documentation for BSA exams, independent audits, and sponsor bank reviews
• Fractional Compliance Leadership — Add hands-on BSA Officer or CCO leadership to manage your AML program and compliance function

Whether you are standing up an AML program for the first time, remediating findings from a BSA exam, or scaling your financial crime compliance alongside new products and partnerships, Equinox Compliance delivers programs that meet the expectations of FinCEN, regulators, auditors, and bank partners.