Fintech & Digital
Payments
"High transaction volume, high regulatory scrutiny"
Regulatory Body
FinCEN, State Money Transmitter Regulators, OCC (for chartered fintechs)
Examiner
IRS BSA Examiners, State Banking Departments, OCC Examiners
Training Frequency
Annual minimum; semi-annual recommended given rapid product evolution
Regulatory Landscape
Fintechs operating as money transmitters are subject to the same BSA requirements as traditional MSBs, but their risk profiles differ significantly. High transaction volumes, digital onboarding, cross-border payments, and novel product structures create AML exposure that generic training does not address. FinCEN has increasingly focused on fintechs in enforcement actions, and state regulators are expanding their oversight of digital payment companies.
BSA/AML Obligations
The following obligations apply to Fintech & Digital Payments under the Bank Secrecy Act and applicable FinCEN guidance.
BSA/AML Program
A written, risk-based AML program tailored to the fintech's specific products, customer base, and transaction types.
Transaction Monitoring
Automated and manual monitoring systems calibrated to the fintech's risk profile and transaction patterns.
SAR Filing
File SARs for transactions of $2,000 or more involving suspected money laundering, fraud, or other financial crimes.
Customer Due Diligence (CDD)
Collect and verify customer identity at onboarding and apply enhanced due diligence for higher-risk customers.
Beneficial Ownership
Identify and verify beneficial owners of legal entity customers as required under FinCEN's CDD Rule.
Training
Role-appropriate AML training for compliance staff, customer service, fraud teams, and product managers.
Risk Indicators
Red Flags to Watch For
- Account opened with minimal information and immediately used for high-value transactions
- Rapid movement of funds through multiple accounts with no apparent business purpose
- Customer uses multiple devices or IP addresses inconsistent with stated location
- Transactions to or from high-risk jurisdictions or sanctioned entities
- Peer-to-peer payment patterns consistent with layering
- Sudden spike in transaction volume inconsistent with account history
- Customer disputes legitimate transactions while conducting suspicious ones
- Use of virtual currencies to obscure transaction trails
Curriculum
Training Topics Covered
- BSA/AML requirements for money transmitters
- Digital payment red flags and typologies
- Synthetic identity fraud and account takeover indicators
- SAR filing for digital payment platforms
- Customer due diligence in digital onboarding
- Beneficial ownership requirements
- Sanctions screening and OFAC compliance
- FinCEN enforcement actions against fintechs
Common Examination Findings
These are the most frequently cited deficiencies in Fintech & Digital Payments AML programs. Addressing them proactively is the difference between a clean examination and a finding.
Transaction monitoring thresholds not calibrated to actual risk
SAR filing backlogs due to insufficient compliance staffing
CDD procedures not updated for new product lines
Training not extended to product and engineering teams
Beneficial ownership records incomplete for business accounts
Get Fintech & Digital Payments AML Training
Industry-specific, NAMLC-verified training through Soflo Consulting and AML Training Center.