Early stage
Registering, launching, or about to
You need a written program, a named compliance lead, and clear answers ready for a bank partner's diligence questions.
Compliance & AML Advisory · Service
Outsourced BSA Officer
A named BSA/AML compliance lead on a monthly engagement, for US payments, money services, fintech and stablecoin companies that are early or growing. Forteris can take the role where your regulators and bank partners accept that, or stand behind the person on your team who holds it, so the program runs day to day and is ready when a regulator or bank partner asks to see it.
Information, not legal advice. This page describes a Forteris service. Forteris is not a law firm and does not give legal advice. Questions that need a legal opinion go to your counsel, and Forteris works alongside them.
Who it is for
Payments companies that need a compliance lead now.
This service is for companies that cannot yet justify a full-time, senior BSA officer, or that have one person carrying the role alone. The work does not wait for the hire.
Growing
Volume, products or states are outpacing the team
Escalations and bank partner requests are arriving faster than one generalist can handle, and the next compliance hire is months away.
Bank-partnered fintechs
Your sponsor bank wants a named lead
Your program agreement asks for a compliance lead and a written program, whether or not your company is itself a money services business.
Stablecoin and digital assets
Moving value on newer rails
You operate as a money services business, or are working out whether you do, and need a program that matches how your product actually moves funds.
The role
What the designated person is responsible for.
This role is often called the BSA officer. If your company is a money services business, 31 CFR 1022.210 sets the minimum for its anti-money laundering program, and one of those minimums is a designated person. In the rule's words:
At a minimum, the program shall: … (2) Designate a person to assure day to day compliance with the program and this chapter. The responsibilities of such person shall include assuring that:
- (i) The money services business properly files reports, and creates and retains records, in accordance with applicable requirements of this chapter;
- (ii) The compliance program is updated as necessary to reflect current requirements of this chapter, and related guidance issued by the Department of the Treasury; and
- (iii) The money services business provides appropriate training and education in accordance with paragraph (d)(3) of this section.
Part (i): reports and records
SAR decision support and a filing calendar
Escalated cases reviewed with your team, each decision documented, and checks that reports went out and records were kept.
Part (ii): a program kept current
Policy and procedure upkeep
The written program and procedures updated as your business and the requirements change, with a change log showing why.
Part (iii): training
Training oversight
A training plan by role, delivered through Forteris Training or your own provider, with completion records you can show an examiner.
What is included
Day-to-day compliance, owned and written down.
Designated BSA/AML officer support
Forteris acts as your designated person where you, your regulators and your bank partners agree, or stands behind the employee you designate. Either way: day-to-day questions, escalations, sign-offs and a single point of contact.
Policy and procedure upkeep
Your written program, procedures and risk assessment kept current as products, volumes, states and requirements change. Each change is logged with the reason for it.
Training oversight
A training plan for each role, delivery through Forteris Training or your existing provider, and completion records kept in one place.
SAR decision support
Escalated cases reviewed with your team. The reasoning behind each file or no-file decision is documented, narratives are drafted for your review, and every deadline is tracked.
Regulator and bank-partner exam support
Document requests prepared, the program walked through with examiners or your bank partner's reviewers, and responses to findings drafted and tracked to closure.
Monthly compliance report
One short report for management or the board: what happened, what was decided and why, what is open, and what is due next.
Compliance calendar
Filings, renewals, reviews and training dates in one shared calendar, so nothing depends on one person's memory.
Not included
Where the line is.
These are outside the monthly engagement. Two are never offered: legal advice, and independent review of a program Forteris helps run. Forteris also does not file reports for you. License applications are scoped and priced separately.
Legal advice
Forteris is not a law firm. Questions that need a legal opinion, such as how a statute applies to a new product, go to your counsel. Forteris works alongside them and gives them the facts they need.
Filing on your behalf
Your company files its own reports and registrations. Forteris does not file them for you.
Independent review of this program
Forteris does not perform the independent review or testing of a program it helps run. That engagement belongs to another firm, and Forteris will help the reviewer get what they need. See the question on this below.
Working the alert queue
First-level alert review stays with your team or your monitoring vendor. Forteris handles what they escalate.
License applications
State money transmitter licensing is scoped and priced separately.
What you provide
The role only works with access and authority.
An executive sponsor
A named executive who can make decisions, approve changes to the program and get answers from the rest of the company.
A written decision on the designation
Written approval from your board or owners of who holds the designated role: Forteris or your own employee.
System access
Read access to your transaction monitoring, case management, onboarding and screening tools, and to wherever the program documents live.
Your current documents
The written program, risk assessment, prior exam, audit and independent review reports, open findings, MSB registration if you have one, and the compliance terms in your bank partner agreements.
People who escalate
A contact in operations, product and engineering, and staff who raise unusual activity promptly.
Timely decisions
Decisions on escalated cases within the turnaround set in the engagement letter, so filing deadlines can be met.
Onboarding
The first four weeks.
Anything urgent, such as an open exam request or a case close to its filing deadline, is handled from the first day. The rest follows this plan.
Week 1
Start
- Engagement letter signed and conflicts checked
- Document request sent and system access set up
- Agree who holds the designation and confirm what your regulators and bank partners expect
Week 2
Read in
- Written program, risk assessment and open findings reviewed
- Recent escalations and the filing calendar reviewed
- Short interviews with operations, product and engineering
Week 3
Plan
- Gaps ranked by risk, with a 90-day plan
- Escalation path and SAR decision workflow in place
- Compliance calendar built
Week 4
Into the monthly rhythm
- Designation documented by your board or owners
- Training plan set
- First monthly report and management update
After week 4: a standing check-in at a cadence agreed with you, the monthly report, and a review of the 90-day plan each quarter.
Engagement
Scoped to what you need, in writing.
Outsourced BSA officer
Priced after a first conversation
Tell us what you need. After a short call about your products, volumes, states and bank partners, and whether Forteris would hold the designation, Forteris confirms whether it can help and sends a written scope and fee.
Discuss with Forteris- Included each month
- Everything under “What is included”, up to the hours set in your written scope
- Additional hours
- At the rate in your written scope, approved by you in advance
- Onboarding (weeks 1–4)
- As set in your written scope
- Term
- As set in your written scope
- Ending the engagement
- On the notice set in your written scope, with a handover of every open case and document
Engagements are formed only by a signed written agreement, which sets the exact scope, hours and turnaround times.
Questions
Common questions.
Can an outside firm be our designated person?
It depends on who regulates you and who you bank with. The federal rule for money services businesses requires the program to designate a person and lists that person's responsibilities, as quoted above. The rule's text does not say whether that person must be an employee.
State regulators and bank partners can set their own expectations, and some companies prefer to designate an employee and have Forteris support that person. Forteris confirms which model fits before anyone is designated.
Will Forteris file our SARs?
No. Forteris helps your team decide, documents the reasoning, and drafts the narrative for your review. Your company files.
For a money services business subject to the federal SAR rule, the deadline is short:
31 CFR 1022.320(b)(3), eCFR as of October 19, 2026“A money services business subject to this section is required to file each SAR no later than 30 calendar days after the date of the initial detection by the money services business of facts that may constitute a basis for filing a SAR under this section.”
Forteris tracks that date on every escalated case.
Can Forteris also do our independent review?
Not for a program Forteris helps run. The federal rule lets an officer or employee conduct the independent review, so long as the reviewer is not the designated person:
31 CFR 1022.210(d)(4), eCFR as of October 19, 2026“Provide for independent review to monitor and maintain an adequate program. … Such review may be conducted by an officer or employee of the money services business so long as the reviewer is not the person designated in paragraph (d)(2) of this section.”
Forteris holds itself to a stricter standard. Where Forteris has designed, built or operated a compliance program, it does not perform the independent review or testing of that program, whether or not Forteris holds the designation. You choose the reviewer, and Forteris gives them what they need.
We work through a sponsor bank and may not be a money services business. Is this for us?
It can be. If your bank partner's agreement asks you to name a compliance lead or keep a written program, the same service applies, and its scope follows that agreement rather than the federal MSB rule.
If you are not sure whether your company is a money services business, start with the free MSB check. It takes about five minutes.
Engage
Discuss your program with Forteris.
New engagements begin with a thirty-minute conversation to scope the role and confirm fit. There is no charge for that call.
Discuss with Forteris30 minutes, no charge
Check whether you need to register as an MSBFree, about 5 minutes
Direct contact
[email protected]Before you write
Please leave customer details, and anything about a SAR, out of a first email.
Confidentiality
All inbound inquiries are treated as confidential. We decline engagements where there is any possibility of conflict.
Not legal advice
This page is information, not legal advice. Forteris is not a law firm.