Fractional BSA/AML Officer and MLRO services for fintechs, banks, and money services businesses

Every FinCEN-registered entity, bank, money transmitter, and fintech operating through a bank partnership is required to designate a BSA/AML Officer. There is no exception, no workaround, and no grace period. Your anti-money laundering compliance program needs a named individual with SAR filing authority, board access, and personal regulatory accountability. A fractional BSA Officer gives you that leadership on a retained basis, with named officer designation and filing authority, without the cost of a full-time executive hire. Equinox Compliance provides fractional AML Officer and MLRO services that go beyond advisory: our officers carry the designation, own the program, and interface with FinCEN and your regulators directly.

Whether you need a designated BSA AML officer, an outsourced BSA officer, or an outsourced AML officer for your fintech, the core requirement is the same: a named anti-money laundering officer with the authority, independence, and accountability that regulators and bank partners expect. At Equinox, we deliver BSA/AML program leadership with named officer accountability and full program ownership.

The Bank Secrecy Act requires every covered financial institution to designate an individual responsible for day-to-day BSA compliance. For banks, this has always been a baseline expectation. For fintechs, MSBs, money transmitters, and companies operating through bank partnerships, the requirement is the same: a named BSA compliance officer with documented authority, independence, and direct access to the board.

What is BSA in banking? It is the foundation of anti-money laundering compliance in the United States. The Bank Secrecy Act and its implementing AML regulations require financial institutions to maintain programs that detect and report suspicious activity, file currency transaction reports, screen against OFAC sanctions lists, and cooperate with FinCEN and law enforcement. The BSA/AML Officer is the individual accountable for all of it.

The challenge for most fintechs, money services businesses, and early-stage financial companies is that a full-time AML compliance officer commands a salary and benefits package the business cannot yet justify. BSA compliance consulting and outsourced AML advisory services have emerged to fill this gap, but most deliver project-based work: policy drafts, risk assessments, and audit preparation. When an examiner or your bank partner asks who owns your anti-money laundering program, “our consultant” does not satisfy the designated AML officer requirements that regulators expect.

A fractional BSA Officer solves this: a senior AML compliance officer embedded in your organization on a retained basis, with the authority, filing privileges, and regulatory fluency to satisfy examiners, auditors, and bank partners. At Equinox, our fractional BSA Officers carry the named officer designation, hold SAR filing authority, and are accountable to your board from day one.

We build and manage your anti-money laundering compliance program from the ground up, with full AML program ownership and certification from your fractional BSA Officer.

• Design BSA/AML compliance programs aligned with FinCEN requirements, FFIEC BSA/AML examination manual guidance, and bank partner expectations
• Establish the five pillars of BSA compliance: internal controls, independent testing (BSA audit), BSA Officer designation, BSA training, and customer due diligence
• Own the anti-money laundering program as your designated BSA AML officer with documented authority and accountability to your board
• Deliver AML program ownership certification and annual BSA/AML board reports documenting program status, risk exposure, and examination readiness

We serve as your designated BSA officer of record with personal regulatory liability, structured to meet the named BSA officer requirement that examiners, FinCEN, and bank partners expect.

• Carry the named officer designation documented in a signed engagement letter with clearly defined BSA AML officer responsibilities and regulatory accountability
• Hold SAR filing authority and oversight as the named individual responsible for suspicious activity report filing and currency transaction report compliance
• Serve as the Qualified Individual (QI) under NMLS when required by your state licensing structure, with the QI designation NMLS appearing on your licensing record
• Satisfy bank partner and BaaS program requirements for a designated AML officer with documented authority and board access

We establish and manage the suspicious activity reporting and currency transaction reporting frameworks your program requires.

• Design SAR filing workflows including detection, escalation, investigation, narrative drafting, and filing with FinCEN
• Conduct SAR narrative review and quality assurance to ensure filings meet regulatory expectations for completeness, accuracy, and timeliness
• Establish CTR filing procedures and currency transaction report compliance controls
• Maintain filing logs, quality metrics, and documentation that demonstrate program effectiveness to examiners and auditors

We design and oversee your transaction monitoring program to ensure it detects, escalates, and documents suspicious activity effectively.

• Design transaction monitoring rules, thresholds, and alert disposition workflows calibrated to your product, customer base, and risk profile
• Conduct periodic transaction monitoring oversight reviews including rule tuning, threshold analysis, and false positive management
• Establish quality assurance programs for alert disposition and case management
• Maintain documentation that demonstrates monitoring program effectiveness for BSA audit and examination purposes

We provide Money Laundering Reporting Officer services with second line of defense review and approval authority for programs that require it.

• Serve as your MLRO with 2LOD review and approval authority over first-line AML operations and case dispositions
• Conduct independent 2LOD review memoranda documenting oversight findings, recommendations, and corrective actions
• Provide MLRO-level review of SAR filing decisions, transaction monitoring alert dispositions, and enhanced due diligence outcomes
• Maintain the independence and documentation standards that satisfy both U.S. and international AML framework expectations

We manage the sanctions compliance component of your BSA/AML program.

• Design OFAC screening procedures for customers, counterparties, and transactions aligned with current sanctions lists and guidance
• Establish screening alert review and disposition workflows with documented escalation procedures
• Coordinate with legal counsel on potential matches, blocked transactions, and filing requirements
• Maintain screening program documentation for examination and audit review

We serve as your primary FinCEN regulator interface and manage the regulatory examination lifecycle for BSA/AML.

• Interface directly with FinCEN, state regulators, bank partner oversight teams, and examiners as your named BSA/AML Officer
• Prepare your organization for BSA/AML examinations including evidence assembly, staff preparation, and document organization
• Manage examiner requests and coordinate communications throughout BSA audit and examination windows
• Support post-examination response drafting, finding remediation, corrective action planning, and consent order compliance

We build BSA/AML programs tailored to the specific requirements of fintechs, money services businesses, and money transmitters.

• Design AML programs for fintechs operating through bank partnerships, including shared responsibility frameworks and sponsor bank reporting requirements
• Build MSB BSA/AML compliance programs for FinCEN-registered money services businesses including FinCEN MSB registration support and ongoing compliance
• Establish money transmitter BSA officer frameworks aligned with state licensing requirements and NMLS obligations
• Design AML programs for payment processors, earned wage access platforms, BNPL providers, crypto MSBs, and digital asset companies

1. Assessment and gap analysis: We evaluate your current BSA/AML program, organizational structure, and regulatory obligations. We identify gaps, assess your designated AML officer requirements, and define the scope of the fractional BSA Officer engagement.
2. Program design and documentation: We design your anti-money laundering program framework, draft policies and procedures, establish filing and monitoring workflows, and formalize the BSA officer of record arrangement including engagement letter, board notification, and FinCEN designation.
3. Implementation and operations: We assume accountability as your named BSA/AML Officer and begin managing day-to-day AML operations. We launch transaction monitoring oversight, SAR/CTR filing programs, and establish the FinCEN and regulator interface.
4. Ongoing management and scaling: We manage recurring BSA/AML deliverables including annual BSA/AML board reports, AML program certification, independent testing coordination (BSA audit), BSA training oversight, and regulatory change monitoring. We refine the program as your business scales and support transition to in-house AML leadership when your organization is ready.

Named officer accountability, not just advisory. Our fractional BSA Officers serve as your BSA officer of record with personal regulatory liability and SAR filing authority. We carry the designation, face the examiners, and own the outcomes.

Full program ownership. We do not deliver reports and walk away. Your fractional BSA Officer owns the anti-money laundering program: filing frameworks, transaction monitoring oversight, OFAC screening, board reporting, and regulator interface. The scope is documented, the authority is real, and the accountability is personal.

Built for fintechs, MSBs, and regulated financial services. We operate across fintech, banking, BaaS, payments, money transmission, earned wage access, BNPL, and digital assets. Your fractional BSA Officer understands AML banking requirements, MSB BSA/AML compliance obligations, and the shared responsibility dynamics of bank partnership programs.

Integrated with your full compliance stack. AML does not operate in isolation. Our BSA Officers coordinate with your CCO, CISO, legal counsel, and risk functions. Equinox provides the full suite of fractional officers, so when your program needs a fractional compliance officer alongside AML coverage, the integration is seamless.

Rapid deployment when it matters. Whether you are responding to a regulatory finding, a consent order, or an examination that requires an immediate named officer, we can execute a BSA/AML Officer designation within days of signing the engagement letter.

• Fintechs that need a named BSA/AML Officer for bank partnership onboarding, regulatory examinations, or sponsor bank oversight requirements
• Money services businesses and money transmitters that need a BSA officer for fintech and MSB operations with FinCEN registration and state licensing compliance
• Early and growth-stage companies that need a senior AML officer but cannot justify a full-time hire
• BaaS programs and bank partnership products that require a BSA officer for their BaaS program with documented authority and board access
• Companies responding to BSA/AML-related exam findings, MRAs, consent orders, or enforcement actions that require immediate named officer designation
• State-licensed entities that need a Qualified Individual (QI) under NMLS alongside BSA/AML Officer designation
• Crypto MSBs, digital asset platforms, and payment processors navigating FinCEN MSB registration and ongoing anti-money laundering compliance
• Organizations preparing for BSA audit or independent testing and needing experienced AML program leadership

• BSA/AML compliance program development — Build the policies, procedures, and controls that form the foundation of your anti-money laundering program
• Fractional CCO — Add named Chief Compliance Officer leadership alongside your BSA Officer for integrated program coverage
• Fractional CISO — Add named information security officer leadership for GLBA, SOC 2, and cybersecurity risk management
• Money transmitter licensing — Navigate the state-by-state licensing process for money transmitters and MSBs
• Compliance management system (CMS) design — Establish the governance structures and control framework that support your BSA/AML program

Whether you need a fractional BSA Officer to build your AML program from the ground up, a named officer of record for regulatory accountability, or MLRO services with 2LOD review authority, Equinox Compliance delivers senior AML leadership calibrated to the regulatory environment you operate in.