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Fractional Compliance Officer

U.S. financial institutions, Money Services Businesses (MSBs), fintech companies, digital asset firms, and other regulated entities are required to maintain effective compliance programs under federal and state law. However, not every organization requires — or can immediately support — a full-time Chief Compliance Officer (CCO).

Fractional Compliance Officer

Fractional Compliance Officer (FCO) ensure your organization remains compliant with:

  • The Bank Secrecy Act (BSA)
  • FinCEN regulations
  • USA PATRIOT Act requirements
  • OFAC sanctions regulations
  • State-level money transmission laws
  • AML program requirements
  • State regulatory examination standards

What Is a Fractional Compliance Officer?

A Fractional Compliance Officer is a senior compliance professional engaged on a flexible basis to oversee and manage your compliance framework.

Under U.S. regulatory expectations, MSBs and other regulated entities must designate a qualified individual responsible for AML compliance. Where appropriate, FinCheck may serve as:

  • Your designated BSA/AML Compliance Officer
  • Interim Chief Compliance Officer
  • Compliance oversight advisor to management and board
  • Regulatory liaison during examinations

We provide experienced leadership without the cost of a full-time executive hire.

Who Needs a Fractional Compliance Officer?

Our U.S.-based FCO service is ideal for:

  • Newly formed MSBs registering with FinCEN
  • State-licensed money transmitters
  • Fintech startups entering regulated markets
  • Digital asset and crypto-related businesses
  • Payment processors and remittance companies
  • Small to mid-sized financial services firms
  • Companies expanding into additional U.S. states
  • Businesses preparing for state or federal examinations

It is particularly valuable when:

  • Launching operations
  • Scaling rapidly
  • Responding to regulatory findings
  • Strengthening internal controls
  • Addressing audit deficiencies

How Our Fractional Compliance Officer Service Works

1. Compliance Program Assessment

It begins with a comprehensive review of your compliance program, including:

  • AML/BSA policies and procedures
  • Customer Identification Program (CIP)
  • Customer Due Diligence (CDD) and EDD processes
  • OFAC sanctions screening controls
  • Suspicious Activity monitoring and reporting procedures
  • Independent audit results
  • Risk assessment methodology
  • State regulatory obligations

This establishes a compliance baseline and identifies regulatory gaps

2. Formal Appointment & Governance Structure

Where required under federal or state law, we can support or serve as your designated Compliance Officer.

We help establish:

  • Clear reporting lines to senior management
  • Board-level reporting protocols
  • Compliance documentation standards
  • Regulatory defensibility framework

We ensure your program meets the four pillars of an effective AML program under U.S. law:

  1. Internal policies and procedures
  2. Designated compliance officer
  3. Ongoing training
  4. Independent testing

3. Ongoing Compliance Oversight

Our ongoing services may include:

  • Oversight of AML transaction monitoring
  • Review and filing guidance for SARs and CTRs
  • OFAC sanctions monitoring supervision
  • Risk assessment updates
  • Regulatory change management
  • Compliance reporting to senior leadership
  • Policy and procedure updates
  • Vendor compliance oversight
  • Employee training coordination

We act as an embedded compliance partner aligned with your business operations.

4. Regulatory Examination & Enforcement Support

If your organization is subject to:

  • State money transmitter examinations
  • FinCEN inquiries
  • BSA audits
  • OFAC reviews
  • Regulatory enforcement actions

We manages:

  • Regulatory communications
  • Examination preparation
  • Documentation production
  • Remediation planning
  • Corrective action implementation
  • Follow-up reporting

Our objective is to ensure your organization is examination-ready and regulator-responsive at all times.

5. Strategic Compliance Advisory

Beyond program oversight, our Fractional Compliance Officer provides forward-looking guidance on:

  • Multi-state expansion strategy
  • Licensing and regulatory registrations
  • New product compliance risk assessments
  • Banking partner compliance expectations
  • Vendor and third-party risk management
  • Mergers and acquisition compliance due diligence

We help your organization anticipate regulatory risk before it becomes a regulatory issue.