Money Transmitter Licensing and AML Compliance for Payroll Companies
FinCheck delivers a state-by-state licensing and exemption analysis, manages money transmitter applications where required, and builds AML and OFAC controls for payroll, contractor payments, payroll cards and earned wage access (EWA).
What makes payroll compliance hard
Money Transmitter Exemptions Vary by State
Some states exempt payroll processors and others don't, so one product can be exempt in one state and require a license in the next.
New Pay Products Bring New Rules
Earned wage access, payroll cards and instant pay can trigger state EWA laws, Reg E requirements and wage payment rules.
Holding Client Funds Brings Scrutiny
Regulators and banks expect client funds to be segregated, reconciled daily and protected if your business fails.
Contractor and Global Payouts Add Risk
Paying contractors and overseas workers requires identity checks, OFAC screening and controls on high-risk payout destinations.
Payroll Fraud and Review Volumes Outpace Your Team
Ghost employees, direct deposit diversion and account takeovers generate alerts faster than a lean team can investigate them.
Experienced Compliance Leaders Are Scarce
Few compliance executives understand both payroll operations and money transmission, and hiring one full time is costly.
Bank Partners Demand Oversight
Your ODFI and sponsor banks expect documented controls, ACH risk management and ongoing reporting before they support your volume.
Partners and Regulators Expect Proof
Banks and state examiners expect independent testing that shows your AML and OFAC controls work in practice.
Our payroll compliance services
Licensing Analysis and Applications
A written, state-by-state view of where you need a license or can rely on an exemption, plus applications and renewals where a license is required.
Pay Product Reviews
Payroll cards, EWA and instant pay reviewed against state and federal rules before launch.
Client Funds Safeguarding Review
A review of your account structure, daily reconciliation and fund protection controls, with clear fixes where gaps exist.
AML and OFAC Program
Controls sized for payroll and contractor payment risk, including onboarding checks, sanctions screening and payout monitoring.
Outsourced Compliance Operations
Trained analysts clearing client onboarding reviews, OFAC hits and fraud alerts, scaling with your payroll volume.
Fractional CCO
Ongoing compliance ownership for growing payroll providers, without the cost of a full-time executive.
Bank Partner Readiness
Due diligence packages, ACH risk documentation and oversight reporting that keep your ODFI and sponsor banks confident.
Independent AML Audit
An annual independent review your bank partners and regulators can rely on, with clear findings and remediation support.
How an engagement works
Discovery Call
We learn your product, money flow, markets and deadlines.
Gap Assessment
We map your obligations and show exactly where you stand.
Build and File
We write the program, prepare filings and set up controls.
Run and Review
Ongoing CCO support, monitoring, audits and renewals.
Frequently Asked Questions
Can FinCheck tell us whether we need a money transmitter license?
Yes. We review your flow of funds and give you a state-by-state analysis of where you need a license and where an exemption applies.
How does FinCheck handle AML and sanctions screening for payroll payments?
We design risk-based AML controls and OFAC screening for employers, employees and contractors, including cross-border payouts.
What if we already rely on a payroll processor exemption?
We check that your structure actually meets each state's exemption conditions and document the position so banks and regulators can see it.
Can FinCheck help select screening and KYB vendors?
Yes. We help you choose and configure sanctions screening and business verification tools for employer onboarding.
Do you provide AML training for our payroll operations team?
Yes. We train operations and client service teams on AML red flags, sanctions and escalation procedures.
Can FinCheck review our earned wage access or payroll card product?
Yes. We review the product against Regulation E and the state earned wage access laws where you operate, before or after launch.