Fractional compliance leadership for fintechs, banks, and financial institutions

Not every organization needs or can afford a full-time Chief Compliance Officer, BSA Officer, or in-house compliance department, but every organization operating in regulated financial services needs experienced compliance leadership.

Equinox Compliance provides hands-on fractional CCO, BSA/AML Officer, and outsourced compliance department services that deliver the seniority, structure, and regulatory credibility of an in-house function without the overhead of building one from scratch. Our leaders have built and managed compliance programs at banks, fintechs, BaaS platforms, and financial technology firms across lending, payments, digital assets, and embedded finance.

Regulators, auditors, and sponsor banks expect to see named, qualified compliance leadership accountable for your programs. For fintechs pursuing state licensing, the NMLS requires a designated CCO and BSA Officer of record. Sponsor banks evaluate whether the compliance function is led by someone with the experience, authority, and operational involvement to actually manage the program, not just sign off on documents.

The challenge is practical. Hiring a senior CCO or BSA Officer is expensive, competitive, and time-consuming. Many organizations, especially those in early or growth stages, cannot justify the cost of a full-time executive-level hire but still need someone who can build the program, manage regulatory relationships, prepare Board materials, lead exam responses, and mentor internal teams. The gap between needing compliance leadership and being able to hire it creates real risk: programs stall, licensing timelines slip, sponsor bank relationships strain, and exam readiness deteriorates.

Fractional compliance leadership closes that gap. It gives your organization access to experienced practitioners who operate as an extension of your team, carrying the title, managing the programs, and engaging directly with regulators, auditors, and bank partners on your behalf. This is not advisory work delivered at arm’s length. It is hands-on leadership embedded in your operations, accountable for outcomes, and available to scale as your business grows.

For organizations with existing compliance staff, fractional leadership adds the strategic oversight, regulatory credibility, and program management discipline that internal teams often lack. For organizations building from the ground up, it provides the foundation to design, implement, and operate a compliance function that satisfies every stakeholder from day one.

We serve as your designated CCO, providing strategic oversight and day-to-day management of your compliance function with the authority, accountability, and regulatory engagement that examiners and bank partners expect.

• Serve as named CCO of record for licensing, regulatory filings, and sponsor bank relationships
• Design and manage the full Compliance Management System including governance, policies, testing, monitoring, training, and reporting
• Prepare and present Board and committee materials on compliance program performance, risk posture, and regulatory developments
• Lead regulatory engagement including exam preparation, examiner meetings, response drafting, and remediation oversight

We serve as your designated BSA/AML Officer, managing your anti-money laundering program with the operational depth and regulatory credibility required by FinCEN, state regulators, and sponsor banks.

• Serve as named BSA/AML Officer of record in the NMLS and all applicable regulatory filings
• Design, implement, and manage the full AML program including risk assessments, CDD/EDD, transaction monitoring, SAR processes, and sanctions screening
• Oversee independent testing, annual risk assessments, and program effectiveness reviews
• Manage regulatory engagement on all BSA/AML matters with examiners, auditors, and bank partners

We operate as your full compliance function, providing the team, structure, and deliverables of an in-house department without the cost and complexity of building one internally.

• Provide a dedicated team covering compliance, AML, risk, testing, monitoring, and governance functions
• Manage all recurring compliance deliverables including policy governance, training programs, testing cycles, Board reporting, and annual assessments
• Staff the compliance function with experienced professionals across executive, director, analyst, and specialist roles
• Scale team capacity as your business grows, new products launch, or regulatory obligations expand

We build your CMS and AML programs from the ground up alongside the leadership engagement, ensuring every component is designed to meet regulatory expectations from the start.

• Design and implement CMS frameworks structured around governance, policies, procedures, testing, monitoring, training, complaint management, and issue management
• Build AML programs including risk assessments, CDD/EDD workflows, transaction monitoring, SAR processes, and sanctions screening
• Establish governance structures including committee charters, reporting lines, escalation protocols, and Board oversight responsibilities
• Deliver phased implementation plans that account for team capacity, licensing timelines, and business priorities

We manage compliance aspects of state and federal licensing alongside your CCO and BSA Officer responsibilities, ensuring your applications and ongoing obligations are handled by the same leadership managing your programs.

• Support MTL, lending, and other state licensing applications with compliance narratives, policies, AML documentation, and organizational materials
• Manage ongoing licensing obligations including renewals, reporting, call reports, and regulator correspondence
• Serve as primary compliance point of contact with state regulators, banking partners, and auditors
• Coordinate regulatory change management to keep licensing documentation aligned with evolving requirements

We advise your executive team on compliance strategy, growth decisions, and regulatory positioning while building the internal capabilities your organization needs over time.

• Guide executives through growth decisions, product launches, market expansion, and partner negotiations with compliance implications
• Mentor and develop internal compliance staff to build long-term organizational capability
• Advise leadership on regulatory trends, enforcement patterns, and emerging compliance expectations
• Support transition planning when the organization is ready to bring compliance leadership in-house

We lead your organization through regulatory exams, independent audits, and sponsor bank reviews with the preparation, presence, and follow-through that these engagements require.

• Prepare documentation, evidence packages, and management responses ahead of exams and audits
• Lead examiner and auditor meetings as your compliance representative
• Manage remediation planning, tracking, and closure for findings and MRAs
• Coordinate ongoing sponsor bank reporting, oversight documentation, and relationship management

1. Assessment and onboarding — We evaluate your current compliance maturity, map your regulatory obligations, and assess your team capacity. We define the scope of the fractional engagement including roles, responsibilities, deliverables, and reporting structures.
2. Program design — We design or refine your CMS and AML frameworks tailored to your products, risk profile, partner requirements, and licensing needs. This includes governance structures, policies, testing plans, training, and reporting.
3. Implementation and operations — We implement compliance programs, assume designated officer roles, and begin managing day-to-day compliance operations. We engage directly with regulators, auditors, and bank partners as your compliance leadership.
4. Ongoing management and scaling — We manage all recurring deliverables, annual assessments, Board reporting, and regulatory change management. We scale the engagement as your business grows, new products launch, or the organization is ready to transition leadership in-house.

• Operators, not advisors. Our fractional leaders have built and run compliance programs at banks, fintechs, and financial technology firms. We do not advise from the sidelines. We carry the title, manage the program, and engage directly with regulators and bank partners on your behalf.
• Full-spectrum compliance depth. A single fractional engagement gives your organization access to expertise across CMS, AML, risk assessment, model governance, fair lending, data governance, licensing, and audit readiness. You get a team, not just a person.
• Regulatory and bank partner credibility. Our leaders have operated on both sides of the regulatory table. Examiners and sponsor banks recognize the depth of experience behind our work, which directly strengthens your compliance posture and partner relationships.
• Built to scale and transition. We design every engagement to scale with your business and transition cleanly when you are ready to bring leadership in-house. We build institutional knowledge, documentation, and team capability so the program outlasts the engagement.
• Cross-sector experience. We operate across fintech, banking, BaaS, embedded finance, lending, payments, and digital assets. This means your compliance leadership reflects the specific regulatory landscape, shared control dynamics, and partner oversight expectations of your business model.

• Fintechs that need a designated CCO or BSA Officer for state licensing, sponsor bank onboarding, or regulatory filings
• Early and growth-stage companies that need experienced compliance leadership but cannot justify a full-time executive hire
• Organizations building CMS and AML programs from the ground up and needing leadership to design, implement, and manage them
• Banks and BaaS platforms that need additional compliance leadership capacity for specific programs, products, or partner oversight
• Companies responding to exam findings, MRAs, or enforcement actions that require experienced leadership to manage remediation
• Organizations preparing for regulatory exams, independent audits, or sponsor bank reviews and needing seasoned compliance representation
• Companies with internal compliance staff that need strategic oversight, mentoring, and program management discipline from senior leadership

• Compliance Management Systems — Design and manage the full CMS framework that fractional leaders build and operate as part of the engagement

• AML, BSA and Financial Crime Programs — Build and manage AML programs alongside BSA Officer responsibilities under the fractional engagement

• Audit and Examination Readiness — Prepare for and lead regulatory exams, audits, and bank partner reviews with dedicated compliance leadership

• Licensing and Regulatory Expansion — Manage the compliance components of state and federal licensing applications and ongoing obligations

Whether you need a designated CCO for licensing, a BSA Officer to manage your AML program, or a full outsourced compliance function to build and run your programs, Equinox Compliance delivers hands-on leadership that meets the expectations of regulators, auditors, and bank partners.