Bank & Fintech Compliance

Bank & Fintech Compliance

BSA/AML program management, regulatory exam readiness, partner bank due diligence, and enterprise risk governance. Built for the institutions and innovators operating in regulated financial services today.

Who We Serve

Community Banks, Regional Institutions, Neobanks, and Payments Platforms

Whether you are a community bank preparing for your next safety and soundness exam, a regional institution responding to MRA findings, or a fintech building compliance infrastructure from the ground up, we bring the institutional depth and regulatory fluency your program needs.

Our principal has worked inside Top 10 U.S. banks, Big 4 advisory firms, and directly with FDIC, OCC, and Federal Reserve examination teams. We understand what regulators are looking for because we have been on both sides of the table.

Sponsor banks overseeing fintech programs can start with fintech partner oversight for sponsor banks. Founders preparing for a bank partner or a raise can start with compliance for fintech founders.

Regulator-facing experience: direct engagement with FinCEN, state banking departments, FDIC and OCC exam teams and the DOJ, plus Big Four and national-firm validation work.

What We Deliver
Services

What We Deliver

BSA/AML Program Governance

End-to-end BSA/AML program design, documentation, and governance aligned to FinCEN, FFIEC, and your primary regulator's expectations.

Examination Readiness

Pre-exam preparation including document assembly, gap analysis, mock exams, and management response coaching.

MRA / MRA+ Response

Structured response plans for Matters Requiring Attention and Matters Requiring Immediate Attention findings from your regulator.

Consent order and MRA remediation

Partner Bank Readiness

Due diligence preparation and compliance infrastructure for fintechs seeking or maintaining bank partnership programs.

Sponsor bank readiness

Transaction Monitoring Tuning

Threshold analysis, scenario optimization, and above-the-line/below-the-line testing for your transaction monitoring system.

CDD/EDD & Customer Risk Rating

Customer due diligence and enhanced due diligence program design, risk rating methodology, and ongoing monitoring frameworks.

FinCEN Registration & MSB Compliance

Money services business registration, state licensing support, and ongoing FinCEN compliance program management.

Money transmitter licensing and FinCEN registration

Crypto & Digital Asset AML

AML program design for digital asset platforms, including wallet screening, travel rule compliance, and blockchain analytics integration.

OFAC & Sanctions Program

Sanctions screening program design, interdiction system testing, and OFAC compliance framework development.

Sanctions screening and OFAC compliance

Independent Testing (2LOD/3LOD)

Independent testing of your BSA/AML program as a second or third line of defense, with regulator-ready reporting.

Independent BSA/AML review

Board & Committee Advisory

Board-level reporting, BSA committee facilitation, and governance advisory for compliance oversight bodies.

BSA Officer Support

Interim and fractional BSA Officer support for institutions in transition, under enforcement action, or building new programs.

BSA/AML officer of record
Common Challenges
Common Challenges

Where Clients Start

Most engagements begin with a specific trigger. Start with the one that matches where you are.

Exam Preparation

Your next exam is approaching and your team needs support assembling documentation, identifying gaps, and preparing management responses.

Partner Bank Pressure

Your bank partner is requiring compliance enhancements, and you need to demonstrate program maturity quickly and credibly.

Program Build-Out

You have the basics in place but need a comprehensive, regulator-ready BSA/AML program with policies, procedures, and testing.

De Novo Fintech Launch

You are launching a new fintech product or platform and need compliance infrastructure built from the ground up.

Why Ethixera vs. Big 4

Big 4 depth without the overhead. Principal-led engagements, faster timelines, and direct access to senior expertise from day one.

Team Experience

Our principal has led BSA/AML programs for Top 10 U.S. banks, community institutions, and fintech platforms across multiple regulatory environments.

The Ethixera team
How We Work

Assess, Build, Evidence, Sustain

Most engagements move through four stages. Where you enter depends on the trigger that brought you to us.

  1. 01

    Assess

    Read the program the way your examiner or bank partner will: risk assessment, policies, customer due diligence, monitoring, screening, SAR decisions and board reporting. Then rank the gaps by risk and by what will be asked for first.

  2. 02

    Build

    Close the gaps with policies, procedures, risk rating methodology, monitoring thresholds and governance your team can run, with the reasoning behind each decision written down.

  3. 03

    Evidence

    Show that the program runs. Pull the records behind each control, document quality assurance and prepare management responses, so every answer points to evidence, not a promise.

  4. 04

    Sustain

    Keep the program current as products, customers and expectations change, with board reporting and follow-up on exam and partner findings. For the independent BSA/AML review, we do not test work we built.

Client Outcomes
Client Outcomes

Testing and Validation Work Behind This Practice

Anonymized engagements reflecting the scope and impact of our work.

FDIC Consent Order

Mid-Size Community Bank · Southeast

Led independent 3rd-line validation testing under FDIC consent order. Developed risk-based test scripts and executed validation across 20+ remediation initiatives spanning AML, GRC, and enterprise governance workstreams.

Engagement via Top 10 National Advisory Firm

Multi-Year Consent Order

Top 10 U.S. Financial Institution

Directed BSA/AML testing and MRA validation across a multi-year remediation program. Managed quality assurance across the KYC customer file refresh program evaluating CDD/EDD standards.

Engagement via Big 4 Advisory Firm

Enterprise Compliance

Top 25 U.S. Banking Institution

Conducted comprehensive 2LOD compliance testing and transactional reviews across the Banking division. Identified deficiencies and recommended actionable remediation strategies.

18-Month Embedded Engagement

“Ethixera brought the depth we expected from a Big 4 firm with the responsiveness and relationship we needed as a growing institution. Their financial crimes advisory work was thorough, practical, and built to last.”

Senior Compliance ExecutiveRegional Banking Institution
FAQ

Questions we hear

What does a BSA/AML program assessment cover?

A focused assessment looks at the whole program the way an examiner or bank partner would. That covers your BSA/AML risk assessment, policies and procedures, customer due diligence and customer risk rating, transaction monitoring and sanctions screening, suspicious activity decisions, training, independent testing history and reporting to the board.

We measure it against FinCEN, FFIEC and your primary regulator's expectations, identify the gaps, prioritize remediation, and give you a clear path forward.

How fast can you get us exam-ready?

It depends on how close the exam is and where the program stands today, so we scope timing on a discovery call instead of quoting a number blind. Engagements are principal-led, with direct access to senior expertise from day one.

We start from the examiner's request list with document assembly and a gap analysis, then run a mock exam and coach management on its responses. The highest-risk gaps get worked first.

Do you work with fintechs or only banks?

Both. We work with community banks, regional institutions, neobanks, money services businesses and payments platforms. For banks, that means exam readiness, MRA response, independent testing and board advisory. Sponsor banks also bring us in for fintech partner oversight. For fintechs, it often starts with sponsor bank readiness, money transmitter licensing or a program build-out.

Can you tune our transaction monitoring without replacing the system?

Yes. Tuning generally works inside the system you already run. We analyze thresholds, optimize scenarios against your customers and products, and run above-the-line and below-the-line testing to show where alerts are likely missed or wasted. We document each change with its rationale and testing evidence, so your examiner and your bank partner can follow why each threshold sits where it does.

Is Ethixera a law firm?

No. Ethixera Advisory is a compliance advisory firm, not a law firm, and does not provide legal advice. We design, test and help run compliance programs, and we work alongside your counsel wherever a question calls for legal judgment.

Not Sure Where Your Program Stands?

We offer a focused BSA/AML program assessment that identifies gaps, prioritizes remediation, and gives you a clear path forward.