Businesses that carry these duties
Federal anti-money-laundering obligations reach well beyond banks. Money services businesses such as money transmitters and check cashers, along with broker-dealers, casinos, and certain dealers in precious metals and stones, generally have program duties, and many must register with FinCEN. Transmitting money usually requires state licensing as well, and New York's Department of Financial Services supervises money transmitters and virtual currency businesses through its own licensing regimes. Whether a particular business model triggers these obligations can be a close question, especially in payments and crypto. Getting that answer wrong can mean operating without a required license, which can be a federal crime in some circumstances.
A program that matches how you actually operate
Regulators and bank partners look less at whether a written policy exists and more at whether it reflects what the business really does. A risk assessment tied to your actual products and customers usually anchors the rest, and monitoring should follow that risk rather than a generic template. Keep records of how alerts were reviewed and why decisions were made, because examiners tend to ask for that trail. Policies written for an earlier version of the business are a common weak spot after growth or a product launch. When a program has fallen out of date, it is better to identify gaps internally than to have an examiner find them.
Where we can help
We work with businesses on licensing questions, program design and updates, responses to exam findings, and requests from banking partners. A first meeting usually covers what your business does, where it operates, how money moves through it, and what regulators or partners have already asked. If you have received an exam report or a formal finding, we look at the timeline for responding and what remediation is realistic. For new ventures, we discuss which licenses may be needed before launch. Because rules in this area change regularly, current requirements are confirmed rather than assumed.
