Compliance your bank partner, your product team and your next investor all trust.
One accountable compliance lead for venture-backed fintech and payments founders, with evidence ready for your bank, board and data room.
Everyone Asks the Same Three Questions
Compliance usually arrives as a request with a deadline: sponsor bank diligence or an audit, a raise, a first money transmitter license, an exam or bank finding, or questions about your AI. Each one asks:
- Who owns compliance?
- What does the program cover?
- What does the evidence show?
One Accountable Lead for Bank, Product and Board
We oversee your compliance program, represent it to your bank partner and report to your board and investors. Our fractional CCO models (Foundational, Active Leadership and Enhanced) size the engagement to your exposure.
We work in your product rhythm, so a new feature or payment rail reaches your bank partner with its risk assessment and controls drafted. The program stays yours, and we mentor the people who run it.
Start Where You Are
A sponsor bank request or audit
A questionnaire, audit or finding needs an owner and evidence that holds up.
Sponsor bank readinessA raise
Investors often ask what your bank partner asks: who owns compliance and what the last test found.
Fractional CCO for fintechsA first money transmitter license
State applications typically expect a written BSA/AML program, control-person disclosures and a designated compliance officer.
Money transmitter licensingAn exam or a bank finding
Gaps found by an examiner or bank partner need an accountable lead, a remediation plan and closure evidence.
Bank and fintech complianceAI in your operations
Your bank partner may ask what each model does, who approved it and how it is tested.
AI governance and data privacyTested to Bank Standards
Sponsor banks judge your program by bank standards. This engagement applied them from inside a bank.
You work directly with founder Victor B. George, JD. Our regulator-facing work includes direct engagement with FinCEN, state banking departments, FDIC and OCC exam teams and the DOJ, plus Big Four and national-firm validation work.
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.
Questions we hear
When should a fintech bring in a fractional CCO?
Ideally before your first sponsor bank diligence request, a first license filing, a raise or a riskier product launch. If an exam or finding has already arrived, start now. See fractional CCO services.
What does a sponsor bank ask for in diligence?
Requests vary, but most cover ownership and control, your license inventory, BSA/AML and sanctions program documents, partner diligence files and recent testing results. Many banks also test compliance independence, access to your customer-ledger data and complaints handling. See sponsor bank readiness.
Can you act as our named compliance officer?
Yes, on defined written terms: a delegation of authority, independence over SAR decisions, and reporting to your board and bank partner. Whether a fractional officer can hold the seat depends on your regulator, licenses and bank partner, so we confirm it with your counsel first. See named BSA/AML officer of record.
What does a first money transmitter license take?
States generally expect a written BSA/AML program, a surety bond, minimum net worth, permissible investments, financial statements and control-person disclosures, usually filed through NMLS. FinCEN generally requires MSB registration too. We prepare and coordinate the filings; legal opinions come from your counsel. See money transmitter licensing.
How do you work with our outside counsel?
Ethixera Advisory is not a law firm and does not provide legal advice. We build and oversee the compliance program; your outside counsel keeps legal interpretation, licensing opinions and privileged matters. We flag questions that need a legal view.
Facing a diligence moment?
Tell us what your bank partner, investor or regulator has asked for, and by when. On a discovery call, we will map what is missing and how to close it.