Oversight of your fintech partners, built by someone who has sat on both sides of the sponsorship.
Independent assessment, diligence and testing of the programs you sponsor. Our founder has tested bank programs from the second and third line, and we work with the fintechs building theirs.
Their Program Is Part of Your Exam
Banking regulators generally hold a bank responsible for activity it runs through a fintech partner, so the partner's BSA/AML program becomes part of your exam.
A new fintech partner
Its program needs diligence before you sign.
An exam on the calendar
Examiners may test how you oversee each partner.
A finding at a partner
It needs an independent test and closure evidence.
An enforcement action
A consent order or MRA reaches your fintech partnerships.
From Onboarding to Closure
Scoped to one partner or a portfolio. Acquiring banks with payment facilitator partners: see merchant acquiring and payfac compliance.
Partner program assessment
A sponsored fintech's BSA/AML and sanctions program, tested against your agreement and risk appetite.
AML program reviewsOnboarding diligence on a sponsored entity
Before you sign: ownership, licenses, program documents, funds flows, testing history and data access.
The sponsor bank diligence file2LOD and 3LOD testing of partner programs
Risk-based test scripts and workpapers your reviewers and examiners can trace to evidence.
Independent BSA/AML testingExam readiness
A pre-exam test of your own partner oversight: approval, monitoring, escalation and board reporting.
BSA/AML exam readinessRemediation validation
Validation of corrective actions under a consent order or MRA, with closure evidence.
Consent order and MRA validationBoth Sides of the Sponsorship
The engagements below show the bank side: bank programs tested and validated by founder Victor B. George, JD, including under enforcement action. On the fintech side, we help fintechs build the programs banks review, as a fractional CCO and on sponsor bank readiness.
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.
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.
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.
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.
Questions we hear
How do you assess a fintech partner's BSA/AML program?
Against the BSA/AML rules that apply, your program agreement and your risk appetite. We review who owns compliance, the risk assessment, due diligence, monitoring, sanctions screening, escalation to the bank and open findings, then sample-test whether the written program is what runs. See independent BSA/AML testing.
Can you test our partner oversight program before the exam?
Yes. We test partner approval, the compliance requirements in partner agreements, monitoring of partner activity, issue escalation and closure, and board reporting, with workpapers an examiner can follow.
Do you work under enforcement actions?
Yes. Our principal has led third-line validation under an FDIC consent order and directed MRA validation across a multi-year remediation program. We support your regulatory relationship, but we never substitute for your BSA Officer or management team in official correspondence.
Can you review a prospective partner before we sign?
Yes. We review ownership and control, licenses, program documents, funds flows and testing history and, where the program is live, sample-test whether it runs as written. The decision stays with the bank. Ethixera Advisory is not a law firm; the agreement's legal terms stay with your counsel.
Is Ethixera independent of the fintechs it reviews for us?
Yes. We do not test programs we built or review a fintech where Ethixera holds the compliance seat. We check conflicts before scoping, disclose any prior work with the fintech, and decline where that work touches what would be tested.
A partner to review, or an exam ahead?
Tell us about the partner, the program agreement and your deadline. We will tell you how we would scope the work.