Compliance insights for banks, fintechs and boards.
Practical analysis on regulatory change, compliance program design, AI governance, and the business of doing compliance well. Written by the people doing the work.
All Insights
Analysis on sponsor bank relationships, BSA/AML programs, enforcement, AI governance, compliance leadership and cross-border work, written for the people who have to act on it.
What the 2026 BSA/AML exam cycle is signaling to mid-size institutions.
Our read on supervisory priorities emerging from recent enforcement actions, and the three program areas we are prioritizing with clients this quarter.
2026 BSA/AML exam cycle signalsWhy African VASPs need Western-grade compliance architecture now, not later.
Kenya’s VASP Act deadline and the FATF mutual evaluation cycle are forcing functions. The institutions that build compliance credibility first will be the ones that capture institutional capital flows.
Compliance architecture for African VASPsThe five questions every board should ask before approving AI deployment.
AI governance does not start with NIST or the EU AI Act. It starts with accountability. Here are the questions that distinguish programs that hold up from programs that collapse on first scrutiny.
Board questions before AI deploymentThe partner bank compliance conversation fintech founders keep avoiding.
Your BaaS sponsor bank is not your regulator, but they act like one. What founders need to understand about the compliance relationship before it becomes an existential risk.
Partner bank compliance for fintechsKnow ethics, know accountability: the conviction behind Ethixera.
Our founder Victor George on the thesis that shaped the firm, and why “ethics training” as practiced across most of the industry is solving the wrong problem.
Know ethics, know accountabilityThe fractional CCO advantage: when it works, when it does not.
Not every organization needs a full-time Chief Compliance Officer. Here is the honest framework we use with clients to determine when a fractional engagement makes sense.
The fractional CCO advantageWhat a sponsor bank's diligence request actually contains, and how to answer it with evidence
The sections a sponsor bank's diligence request typically covers, what the bank is testing behind each one, and how to answer with evidence instead of promises.
Sponsor bank diligence requestsHow to prepare for a sponsor bank compliance audit with a two-person compliance team
How a small compliance team scopes a sponsor bank audit, maps its evidence, tests itself first and walks into fieldwork without surprises.
Sponsor bank audit preparation for small teamsFractional CCO or BSA officer of record: which seat your bank partner is asking for
How to read a bank partner's request and tell whether it wants compliance program leadership, a named BSA/AML officer of record, or both.
Fractional CCO or BSA officer of recordThe independent BSA/AML review for MSBs: what examiners and bank partners expect to see
What the BSA rules require of an MSB's independent review, who may perform it, and what examiners and bank partners read for in the report.
The independent BSA/AML review for MSBsMerchant risk tiers for payment facilitators: how underwriting standards get written
How payment facilitators write tier criteria a reviewer can apply, set what each tier requires, and evidence the standard their acquiring partner will test.
Merchant risk tiers for payment facilitatorsPut the analysis to work. The services these pieces connect to: sponsor bank readiness, independent BSA/AML review, consent order remediation, fractional CCO services, AI governance and data privacy and U.S.-Africa cross-border compliance.
Talk to a practitioner, not a pitch team.
Tell us where you are: an exam notice, a bank-partner request, a raise, an enforcement action. We will tell you what it takes.