Industry
Fintech & financial platforms.
Banking-as-a-service, payments, lending, crypto-on-ramps. Sponsor-bank partnerships, third-party risk, money-transmitter licensing.
Fintechs sit inside a regulatory architecture they often did not design: a sponsor bank that holds the charter, a state-by-state money-transmitter licensing burden, a CFPB or state AG with consumer-protection authority, and a set of third-party vendors that look more like critical infrastructure than vendors. The control environment was usually built fast, and the team that built it has now turned over twice.
Our practice for fintech and financial platforms is built around two recurring scenarios. The first is sponsor-bank readiness — making sure the institution can survive the sponsor's annual diligence with the AML/BSA, fair-lending, complaints, and operations posture the sponsor is responsible for. The second is institutional readiness for the next stage — whether that's a Series D with a strategic acquirer in the diligence room, a charter application, or an S-1.
Sponsor banks ended several large fintech relationships in the past 36 months. The pattern was the same: the sponsor's diligence found gaps the fintech did not know it had. We help institutions not be the next one.
| Regulator | Authority |
|---|---|
| Sponsor bank's regulator | Diligence on AML, fair lending, ops |
| State regulators · MMC | NMLS-based MTL framework |
| CFPB · state AGs | UDAAP and product surface area |
| FinCEN | SAR / CTR, sanctions screening |
| SEC · CFTC · OCC | Platform-specific regimes (crypto) |
| State AGs · NYDFS | Data residency, breach notification |
- AML & sanctions — Sponsor-grade BSA programs, TM tuning for fintech-rail typologies, sanctions screening at scale.
- IT audit — Vendor risk, cloud configuration, identity, and data-residency for platforms operating at speed.
- Model validation — AI/ML underwriting, fraud detection, and customer-facing models — validated for fairness and drift.
- IPO readiness — For fintechs preparing for the next stage — a control environment that survives diligence.
A BaaS-fronted neobank with 2.4M customers was 90 days from its sponsor bank's annual diligence cycle and the CRO had reason to believe the AML and TM posture would not pass. Edgar led model and TM work; Andres led the audit posture and the sponsor-facing communication.
What the audit committee saw
- Finding 01 TM tuning study completed; new typologies added for layering through fintech rails; alert volumes reduced 38%.
- Finding 02 Sanctions-screening configuration corrected; false-positive rate dropped from 94% to 71%.
- Finding 03 Sponsor-bank diligence completed with no material findings — relationship continued.