Compliance, Risk & Operations

Navigate regulation and build scalable operations, with operators who've run card programs.

Led by Scott Grimes

Whether you're launching a new program or optimizing existing operations, we help you navigate complex regulatory landscapes and build scalable systems. With deep expertise in fintech compliance, fraud risk management, and operational infrastructure, we act as an extension of your team, bringing clarity, structure, and speed to your business. These services prepare your program for rapid bank approval and initial compliance, then scale with you as you bring more in-house. We also support sponsor banks and community banks overseeing their fintech and BaaS partner programs.

What's included

Compliance

  • Regulatory Guidance
  • Policy Development
  • Compliance Program Design

Risk Management

  • Fraud Prevention Strategy
  • KYC/AML Program Setup
  • Risk-Managed Launch Planning

Operations

  • Staffing & Resource Planning
  • Customer Support Infrastructure
  • Operational Readiness

Core offerings

Bank Approval & Launch Readiness

The fastest path to launch runs through sponsor bank approval.

We help develop the policies, procedures, controls, and documentation your bank expects to see before approving a program. We coordinate with your partners, manage the approval process, review marketing materials, and help address questions as they arise.

Our goal is simple: help you get through approval efficiently and avoid the delays that come from incomplete documentation, unclear ownership, or preventable compliance gaps.

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KYC/AML Program Design

Effective compliance programs create a foundation for growth.

We design KYC and AML programs that balance customer experience, risk management, and regulatory expectations. Programs are built to the Bank Secrecy Act (BSA), FinCEN guidance, and the FFIEC BSA/AML Examination Manual, with consumer-protection controls aligned to Regulation E and UDAAP. This includes policies, procedures, controls, escalation paths, and operational workflows that support both partner-bank requirements and long-term scalability.

The result is a program designed to pass review today and support your business as it grows.

Fractional Compliance & Operations Leadership

Many fintech teams need experienced compliance and operations leadership before they are ready to hire it full-time.

We provide fractional compliance and operational leadership to help guide programs through launch, partner reviews, growth, and operational maturity. This can include serving as a named BSA/AML officer, supporting risk operations, overseeing customer support functions, and helping build the processes required to scale.

Our goal is to provide experienced leadership while helping your organization develop the internal capabilities needed over time.

How we work

We tailor support based on your stage of growth and the needs of your program.

Some engagements focus on policy development and launch readiness. Others provide ongoing compliance, risk, and operational support before and after launch. We also support organizations through fractional leadership engagements that help bridge critical gaps while internal teams are being built.

Most engagements are structured as retainers, with the goal of helping your organization become increasingly self-sufficient as it grows.

Frequently asked questions

Can you help us get through sponsor bank approval?

Yes. We help develop the policies, procedures, and documentation required by your sponsor bank, coordinate the approval process, review marketing materials, and support ongoing discussions with your partners. The goal is to reduce delays and help your team move efficiently through approval.

How do you design a KYC/AML program?

We start by understanding your product, customer base, and risk profile. From there, we develop a risk-based framework of policies, procedures, controls, and workflows needed to satisfy partner-bank requirements and support long-term growth.

Do you offer fractional compliance or operations leadership?

Yes. We provide fractional compliance and operational leadership for organizations that need experienced guidance before making a full-time hire. This can include compliance oversight, risk management, customer support operations, and launch readiness.

When should we start compliance work?

Earlier than most teams think. Many of the delays that occur during sponsor bank review can be traced back to decisions made months before approval begins. Starting compliance work early helps identify gaps, build required documentation, and avoid unnecessary delays later in the process.

Do you conduct audits?

Yes. We are experienced in internal audit preparation and delivery for AML/BSA audits, as well as compliance program audits.

Ready to get started?

Get in touch