Professional Compliance Opinion
Professional Guidance on
AML/CFT and Sanctions Compliance
When fintechs, MSBs, or innovative payments businesses need to define their model clearly—to approach payments attorneys, regulators, or banks—clarity matters.
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MSB Compliance Inc. provides expert guidance to help clients describe their business operations and flow of funds from a Bank Secrecy Act (BSA) perspective. Our Compliance Opinion service helps uncover and validate the actual or proposed fact pattern so it can be clearly understood, reviewed, and relied upon.
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The resulting opinion is a professional, standards-aligned analysis—used to support subsequent legal analysis, licensing applications, and bank onboarding.
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We are not attorneys and do not engage in the provision of legal advice.
What This Service Provides
Our role is to help define and validate the fact pattern—specifically the business model and flow of funds—and to provide a regulatory compliance opinion based on that fact pattern. This provides a clear foundation for legal counsel to assess legal exposure and licensing obligations.
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We assist institutions in determining whether the business model may include money transmission, other MSB activities, third-party payment processing, Software-as-a-Service (SaaS) functionality, or a combination thereof.
Too often, legal reviews become delayed—or more expensive—because internal teams can’t present a clear, accurate, and logically structured fact pattern. Without foundational compliance clarity, legal counsel must first interpret or untangle the business model before conducting their analysis. We close that gap.
Why Institutions Engage Us
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Their flow of funds and operations are complex—and they need help defining the fact pattern before seeking legal review.
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Their compliance officer or general counsel worked with us before and trusts our work to support honest, objective board-level reporting.
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They need documentation that can support subsequent legal analysis, licensing applications, or sponsor bank onboarding.
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They value a professional opinion built on deep experience with MSBs, fintechs, payment processors, and AML/CFT expectations.
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They want clarity and structure their attorneys—and regulators—can trust to support their fintech and MSB relationships.
What's Included?
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Business Model Review:
Evaluate current and proposed operations to determine applicable regulatory obligations.
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Documentation of the Flow of Funds:
Draft a clear, logically structured business model description and a detailed fund flow chart.
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Regulatory Compliance Opinion:
Prepare a professional, standards-aligned opinion outlining AML/CFT and Sanctions implications with appropriate citations.
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Collaboration with Legal Counsel:
Coordinate with internal or external legal counsel to confirm the opinion aligns with their legal analysis needs.
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Referral for Legal Engagement (if needed):
If the client doesn’t have legal counsel, we can refer them to trusted payments attorneys from our professional network.
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FinCEN Advisory Ruling (if applicable):
Assist in evaluating whether to request a FinCEN advisory ruling and prepare a draft submission for legal counsel to finalize.
Our Position and Role
MSB Compliance Inc. brings structure, experience, and clear documentation to complex regulatory fact patterns. Our work supports legal clarity, but we do not act as legal counsel.
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Our team does not provide legal advice or legal opinions. We encourage review of our Compliance Opinion by qualified payments attorneys, who may incorporate it into legal analysis based on the validated fact pattern and business model.