The Basics

The Basics

What AML Compliance Means for Fintechs

AML compliance means having controls in place to detect and report suspicious financial activity. For fintechs, this often includes things like customer identity checks, transaction monitoring, and filing reports with regulators like FinCEN.

If your business moves money, handles assets, or offers financial products, regulators expect you to have a risk-based AML program. This applies to money transmitters, crypto platforms, broker-dealers, and other regulatory verticals.

Regulators review your AML program during audits, exams, and license applications

Weak or missing AML controls are one of the most common causes of enforcement actions

Banking and payment partners often require strong AML processes before working with you

You may be required to report suspicious activity through SARs or other filings

Your risk profile can change as your products or customer base evolve

Poor AML practices can expose your platform to misuse by fraudsters or sanctioned parties

Written AML Policies

Regulators expect to see documented procedures that explain how your company handles AML requirements, from onboarding to monitoring and reporting. These policies should match your actual operations.

Written AML Policies

Regulators expect to see documented procedures that explain how your company handles AML requirements, from onboarding to monitoring and reporting. These policies should match your actual operations.

Written AML Policies

Regulators expect to see documented procedures that explain how your company handles AML requirements, from onboarding to monitoring and reporting. These policies should match your actual operations.

Clear Roles and Oversight

Your program should name the person or team responsible for AML compliance and show how responsibilities are assigned across your organization.

Clear Roles and Oversight

Your program should name the person or team responsible for AML compliance and show how responsibilities are assigned across your organization.

Clear Roles and Oversight

Your program should name the person or team responsible for AML compliance and show how responsibilities are assigned across your organization.

Ongoing Transaction Monitoring

Fintechs are expected to have systems in place to detect unusual or suspicious activity. This includes setting rules, reviewing alerts, and keeping records of how issues are handled.

Ongoing Transaction Monitoring

Fintechs are expected to have systems in place to detect unusual or suspicious activity. This includes setting rules, reviewing alerts, and keeping records of how issues are handled.

Ongoing Transaction Monitoring

Fintechs are expected to have systems in place to detect unusual or suspicious activity. This includes setting rules, reviewing alerts, and keeping records of how issues are handled.

Timely SAR Filings

If your team identifies suspicious activity, regulators expect you to investigate and file Suspicious Activity Reports (SARs) on time. Delays or missed reports are common exam findings.

Timely SAR Filings

If your team identifies suspicious activity, regulators expect you to investigate and file Suspicious Activity Reports (SARs) on time. Delays or missed reports are common exam findings.

Timely SAR Filings

If your team identifies suspicious activity, regulators expect you to investigate and file Suspicious Activity Reports (SARs) on time. Delays or missed reports are common exam findings.

Risk-Based Across Markets

Your AML program should reflect the risks of your customers and products. If you operate across multiple states or countries, regulators also expect your controls to account for that.

Risk-Based Across Markets

Your AML program should reflect the risks of your customers and products. If you operate across multiple states or countries, regulators also expect your controls to account for that.

Risk-Based Across Markets

Your AML program should reflect the risks of your customers and products. If you operate across multiple states or countries, regulators also expect your controls to account for that.

Regulatory Expectations

Regulatory Expectations

Regulatory Expectations

What Regulators Expect from Your AML Program

Regulators like FinCEN, the SEC, and state agencies expect fintechs to have AML programs that reflect their actual business risks. That includes written policies, clear roles and responsibilities, customer identity checks, ongoing monitoring, and timely reporting of suspicious activity.

Mistakes on a Fintechd ocument
Mistakes on a Fintechd ocument

Mistakes

Mistakes

Mistakes

Common AML Mistakes We See in Fintech

Treating AML like a one-time setup instead of an ongoing process

Using generic policies that don’t reflect your product, customer base, or risks

Relying too heavily on vendors without understanding what they actually do

Delaying or skipping suspicious activity reports

Launching new features without updating your risk assessment or controls

Not assigning clear responsibility for daily AML tasks

Scenarios

Scenarios

Scenarios

When AML Programs Don’t Keep Up

These examples show how gaps in AML programs can lead to compliance issues, especially when fintechs grow fast or change direction. We help fill those gaps before they become findings.

Regulatory platform warning
Regulatory platform warning
Regulatory platform warning

Scenario 1

The Issue: A crypto platform scaled quickly but didn’t update its monitoring rules.

What Happened: As volume grew, the system failed to flag high-risk patterns. The company missed multiple suspicious transactions.

How We’d Approach It: At InnReg, we’d reassess the transaction monitoring setup based on volume, activity types, and red flag indicators, then help recalibrate rules and alerts to fit the platform’s growth.

Scenario 2

The Issue: A lending app used a vendor for KYC that didn’t understand the full process.

What Happened: The vendor skipped key verification steps, and several fake accounts got through.

How We’d Approach It: At InnReg, we’d map out the full onboarding flow, vet the vendor’s controls, and clarify which parts of KYC need internal oversight or backup checks.

Employee submitting a file
Employee submitting a file
A frustrated team
A frustrated team
A frustrated team

Scenario 3

The Issue: A neobank expanded into new markets but kept the original AML policy.

What Happened: The policy didn’t address cross-border risks, triggering findings in a partner audit.

How We’d Approach It: At InnReg, we would update the AML policy with procedures specific to international activity and review how transaction monitoring adjusts to new customer types.

Scenario 4

How We Help

How We Help

How We Help

InnReg’s Approach to AML Compliance for Fintechs

InnReg helps fintechs build AML programs that are practical, right-sized, and prepared to evolve with the business. Whether you need to draft policies, build workflows, or run day-to-day operations, we plug in where you need us most.

We Build Risk-Based AML Policies

We draft AML policies and procedures that reflect your products, customer base, and regulatory obligations.

We Build Risk-Based AML Policies

We draft AML policies and procedures that reflect your products, customer base, and regulatory obligations.

We Build Risk-Based AML Policies

We draft AML policies and procedures that reflect your products, customer base, and regulatory obligations.

We Set Up Monitoring and Reporting Processes

We help configure systems to detect suspicious activity, respond to alerts, and document the next steps.

We Set Up Monitoring and Reporting Processes

We help configure systems to detect suspicious activity, respond to alerts, and document the next steps.

We Set Up Monitoring and Reporting Processes

We help configure systems to detect suspicious activity, respond to alerts, and document the next steps.

We Help You File SARs and Track Reviews

We guide you through SAR filings and help create workflows to track investigations and decisions.

We Help You File SARs and Track Reviews

We guide you through SAR filings and help create workflows to track investigations and decisions.

We Help You File SARs and Track Reviews

We guide you through SAR filings and help create workflows to track investigations and decisions.

We Review and Update Your Program Over Time

As your business grows, the InnReg team revisits your AML setup to reflect new risks, rules, or markets

We Review and Update Your Program Over Time

As your business grows, the InnReg team revisits your AML setup to reflect new risks, rules, or markets

We Review and Update Your Program Over Time

As your business grows, the InnReg team revisits your AML setup to reflect new risks, rules, or markets

We Work Inside Your Tools and Systems

We use your tools and processes instead of creating parallel systems.

We Work Inside Your Tools and Systems

We use your tools and processes instead of creating parallel systems.

Resources

Resources

Resources

Latest Content

FAQ

FAQ

FAQ

Frequently Asked Questions

Are broker-dealers required to maintain an AML program?

Are broker-dealers required to maintain an AML program?

Are broker-dealers required to maintain an AML program?

Do ATSs need to follow AML rules?

Do ATSs need to follow AML rules?

Do ATSs need to follow AML rules?

What happens if I don’t file SARs or CTRs?

What happens if I don’t file SARs or CTRs?

What happens if I don’t file SARs or CTRs?

What’s required for a mortgage lender’s anti-money laundering program?

What’s required for a mortgage lender’s anti-money laundering program?

What’s required for a mortgage lender’s anti-money laundering program?

Do commercial lenders need an AML program?

Do commercial lenders need an AML program?

Do commercial lenders need an AML program?

What are the AML obligations for a money broker?

What are the AML obligations for a money broker?

What are the AML obligations for a money broker?

Do I need an AML program for a credit builder product?

Do I need an AML program for a credit builder product?

Do I need an AML program for a credit builder product?

Can digital banks outsource their AML function?

Can digital banks outsource their AML function?

Can digital banks outsource their AML function?

What AML requirements apply to US payment companies?

What AML requirements apply to US payment companies?

What AML requirements apply to US payment companies?

Do I need to file suspicious activity reports (SARs) as a payment services provider?

Do I need to file suspicious activity reports (SARs) as a payment services provider?

Do I need to file suspicious activity reports (SARs) as a payment services provider?

Contact Us

Contact Us

Contact Us

Signs Your AML Program Needs an Update

AML compliance can fall out of step as your fintech evolves. If any of these situations sound familiar, we can help.

Your AML procedures haven’t been reviewed in over a year

Your SAR process isn’t documented or assigned to specific people

You’ve received findings or requests from a regulator or banking partner

Your monitoring system is flagging too much or not enough

Your compliance team is stretched too thin to keep up with reviews

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© 2025 InnReg LLC

305-908-1160

LinkedIn Innreg
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9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156

The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.

© 2025 InnReg LLC

305-908-1160

LinkedIn Innreg
X InnReg

9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156

The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.

© 2025 InnReg LLC

305-908-1160

LinkedIn Innreg
X InnReg

9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156

The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.