Industry · 05/05
Fintech & financial platforms.
Banking-as-a-service, payments, lending, crypto-on-ramps. Sponsor-bank partnerships, third-party risk, money-transmitter licensing.
Banking-as-a-service, payments, lending, crypto-on-ramps. Sponsor-bank partnerships, third-party risk, money-transmitter licensing.
A sponsor bank can end a fintech in six weeks. Build for them.
Fintechs sit inside a regulatory architecture they often did not design: a sponsor bank that holds the charter, a state-by-state money-transmitter licensing burden, a CFPB or state AG with consumer-protection authority, and a set of third-party vendors that look more like critical infrastructure than vendors. The control environment was usually built fast, and the team that built it has now turned over twice.
Our practice for fintech and financial platforms is built around two recurring scenarios. The first is sponsor-bank readiness — making sure the institution can survive the sponsor's annual diligence with the AML/BSA, fair-lending, complaints, and operations posture the sponsor is responsible for. The second is institutional readiness for the next stage — whether that's a Series D with a strategic acquirer in the diligence room, a charter application, or an S-1.
Sponsor banks ended several large fintech relationships in the past 36 months. The pattern was the same: the sponsor's diligence found gaps the fintech did not know it had. We help institutions not be the next one.
A BaaS-fronted neobank with 2.4M customers was 90 days from its sponsor bank's annual diligence cycle and the CRO had reason to believe the AML and TM posture would not pass. We were brought in for a sponsor-grade pre-read: BSA program assessment, TM tuning study, sanctions-screening calibration, and a board-reporting package that the sponsor's risk team would recognize. Edgar led model and TM work; Andres led the audit posture and the sponsor-facing communication.