Fintech Compliance Expert for Sponsor Bank Onboarding

U.S. Fintech / Sponsor Bank Compliance Specialist – Banking-as-a-Service & Card Program

Project Details

**Budget:** USD 500 –1,000 (open to proposals based on experience and scope)

We are a global travel and fintech platform currently undergoing due diligence and onboarding with a **U.S. regulated banking partner** for an embedded banking, payments and card-issuing program.

The banking partner has provided us with a comprehensive **Fintech Banking Questionnaire, compliance requirements, business projections template and due-diligence framework**.

We are looking for an experienced **U.S. fintech compliance specialist, fractional Chief Compliance Officer (CCO), BSA/AML consultant, or regulatory advisory professional** to work directly with our management team and help us prepare the **complete compliance and due-diligence submission**.

This is not simply a document-review assignment. We need someone capable of reviewing the bank's requirements, identifying gaps in our existing framework, preparing missing policies and controls, completing the required compliance sections, and supporting us through follow-up questions from the banking partner.

### Program Overview

The proposed banking relationship may include:

* Banking-as-a-Service (BaaS)
* Customer USD accounts / transaction accounts
* Subledger infrastructure
* ACH payments
* Domestic wire transfers
* Instant payments
* Card issuing
* Physical and virtual debit cards
* International payments
* Embedded banking APIs
* Stablecoin / on-chain payment functionality
* Fiat and digital-asset related payment flows

Our platform has an international customer base, so experience with **cross-border payments, fintech, cards and digital assets/stablecoins** would be highly advantageous.

### Scope of Work

The selected specialist will be expected to:

**1. Bank Requirement & Gap Assessment**

* Review the complete banking partner compliance package.
* Review the Fintech Banking Questionnaire and associated requirements.
* Assess our existing compliance policies, procedures and controls.
* Identify missing or insufficient documentation.
* Produce a clear remediation and submission checklist.

**2. Fintech Banking Questionnaire**

Assist us in preparing comprehensive responses covering:

* Company and business model
* Regulatory status
* Banking products and services
* Customer profile and geographic footprint
* Funds flows
* Customer onboarding
* Financial and business viability
* Program experience
* Management and governance
* AML/CFT and OFAC
* Compliance Management System (CMS)
* Customer Identification Program (CIP)
* Customer Due Diligence (CDD)
* Transaction monitoring
* Fraud management
* Complaint handling
* Third-party/vendor risk management
* Compliance testing and monitoring
* Policies and procedures

**3. AML/CFT & BSA Framework**

Review, enhance or develop:

* AML/CFT Policy
* BSA/AML compliance framework
* Customer Identification Program (CIP)
* Customer Due Diligence (CDD)
* Enhanced Due Diligence (EDD)
* Customer risk-rating methodology
* Beneficial ownership procedures
* Suspicious activity escalation procedures
* AML governance and Board oversight

**4. OFAC & Sanctions Compliance**

Develop or review:

* OFAC compliance framework
* Sanctions screening procedures
* PEP screening
* Adverse-media screening
* Escalation and investigation procedures
* Sanctions risk assessment

**5. Transaction Monitoring**

Help design and document:

* Transaction-monitoring framework
* Monitoring rules and scenarios
* Alert-generation methodology
* Alert investigation procedures
* Case-management procedures
* Escalation framework
* Suspicious activity handling
* Monitoring of cross-border transactions
* Monitoring considerations for digital assets/stablecoins

**6. Compliance Management System (CMS)**

Develop or enhance a bank-ready CMS covering:

* Compliance governance
* Compliance Officer responsibilities
* Board and senior-management oversight
* Compliance risk assessments
* Monitoring and testing
* Compliance training
* Issue management
* Change management
* Complaint management
* Quality assurance
* Regulatory reporting
* Third-party oversight

**7. Fraud Management Program**

Develop/review:

* Fraud prevention framework
* Fraud monitoring
* Fraud detection rules
* Investigation procedures
* Escalation protocols
* Account/card restrictions
* Fraud reporting
* Fraud governance

**8. Third-Party Risk Management**

Help document our oversight framework for critical vendors including:

* KYC/KYB providers
* Transaction-monitoring providers
* Blockchain analytics providers
* Card processors
* Payment providers
* Cloud/technology providers
* Other critical fintech infrastructure partners

This should include due diligence, risk classification, approval, ongoing monitoring and vendor review procedures.

**9. Customer Complaint & Issue Management**

Prepare appropriate procedures covering:

* Complaint intake
* Classification
* Investigation
* Escalation
* Resolution
* Regulatory complaints
* Root-cause analysis
* Corrective action
* Complaint reporting
* Issue and remediation tracking

**10. Funds Flow & Product Documentation**

Work with our product and technical teams to prepare/review:

* End-to-end funds flow
* Customer onboarding flow
* Account funding flow
* ACH flow
* Wire flow
* Card transaction flow
* Stablecoin/fiat conversion flow where applicable
* Settlement and reconciliation flow
* Roles and responsibilities of each infrastructure partner

**11. Bank Due-Diligence Support**

We require support beyond the initial submission.

The selected consultant should be available to:

* Review the final submission before delivery.
* Respond to follow-up questions from the banking partner.
* Assist with remediation requests.
* Participate in compliance calls where required.
* Update policies or procedures following bank feedback.
* Support us through the due-diligence and onboarding process.

### Required Deliverables

At minimum, we expect:

1. Completed/reviewed Fintech Banking Questionnaire.
2. Compliance gap assessment.
3. AML/CFT/BSA framework.
4. KYC/CIP/CDD/EDD procedures.
5. OFAC and sanctions framework.
6. Transaction Monitoring framework.
7. Fraud Management Program.
8. Compliance Management System (CMS).
9. Compliance Risk Assessment.
10. Complaint Management Policy.
11. Issue Management framework.
12. Third-Party Risk Management Policy.
13. Compliance Training framework.
14. Compliance Monitoring & Testing framework.
15. Customer onboarding and funds-flow documentation.
16. Review of business projections from a compliance/risk perspective.
17. Final bank-readiness review.
18. Support with banking-partner follow-up questions and remediation.

All documentation should be professional and suitable for submission to a **U.S. regulated banking institution**.

### Required Experience

Applicants should have demonstrable experience in one or more of the following:

* U.S. fintech compliance
* Sponsor-bank onboarding
* Banking-as-a-Service (BaaS)
* BSA/AML compliance
* OFAC compliance
* Fintech Compliance Management Systems
* Card issuing / BIN sponsorship
* ACH and payment programs
* Embedded banking
* Money transmission
* Cross-border payments
* Digital assets / stablecoins
* Transaction monitoring
* Fintech bank due diligence

**Strong preference will be given to candidates who have previously helped fintech companies onboard with U.S. sponsor banks or Banking-as-a-Service providers.**

Experience working with banks such as Cross River, Lead Bank, Column, Evolve, Pathward, Sutton, Celtic, WebBank or similar U.S. fintech banking institutions would be particularly relevant.

### When Applying, Please Provide

Please answer the following:

1. Have you previously supported a fintech through U.S. sponsor-bank onboarding? Please describe your experience.
2. Have you built or reviewed a BSA/AML and Compliance Management System for a fintech?
3. Have you completed sponsor-bank due-diligence questionnaires?
4. Do you have experience with card issuing, BaaS, ACH or embedded banking?
5. Do you have experience with crypto, stablecoins or digital-asset businesses?
6. Have you worked directly with U.S. banks or bank compliance teams?
7. Can you assist with drafting policies rather than only reviewing them?
8. Can you remain involved during follow-up questions and remediation?
9. Please provide examples of comparable engagements, subject to confidentiality restrictions.
10. Please provide your proposed fixed fee and expected turnaround time.

### Preferred Qualifications

Relevant qualifications such as **CAMS, CRCM, CFE, CFCS or equivalent compliance credentials** are preferred but not mandatory where the applicant can demonstrate substantial practical U.S. fintech banking experience.

Timeline

We are ready to begin **immediately**.

We would ideally like the initial gap assessment and questionnaire review completed within **5–7 business days**, followed by preparation/remediation of the required policies and documentation.

This may lead to an **ongoing fractional compliance / advisory engagement** as we progress through bank onboarding and launch.

**Please do not apply if your experience is limited to generic AML documentation. We specifically require hands-on U.S. fintech, sponsor-bank, payments or Banking-as-a-Service compliance experience.**