Services for institutions engaged with the MSB sector.
Banks see transactions and ask “is this normal?” — we know whether it is. MSBs use industry shorthand for things banks call by their formal names — we translate between them. MSBs that aren't ready to be banked aren't turned away — we rehabilitate them into the pipeline. Across program review, program design, referrals, rehabilitation, and strategic advisory, our services are scoped to the knowledge gaps that institutional engagement with the sector exposes.
What we deliver
MSB-customer program review. Independent review of a bank's MSB program against FFIEC and FinCEN expectations. We assess enhanced due diligence methodology, monitoring rules calibrated to MSB activity, governance documentation, and the operational handoffs between front-office and BSA functions. Engagements close with a report scoped to examiner-grade scrutiny.
Program design and policy development. For institutions building or refining an MSB-customer program, we draft policies, procedures, transaction monitoring frameworks, and governance documentation — tailored to the institution's risk appetite, regulatory supervisor, and target MSB segment.
MSB referrals to banking partners. Institutions in our network receive referrals of MSB operators we have already assessed for compliance posture, transaction volume, and operational maturity. Vetted referrals reduce onboarding cost and concentrate institutional review attention where it actually adds value.
MSB rehabilitation. Not every MSB that approaches our network is ready to be banked. Rather than turn them away, we engage them on the gaps — program build-out, training, governance, transaction monitoring uplift — and re-present them when their posture supports the engagement. The result is a deeper, more durable pipeline of bankable operators over time.
Banking introductions for senior MSB operators. Larger MSB operators — payment processors, multi-state money transmitters, established check-cashing chains — engage us to navigate banking relationships at the level their business requires.
Strategic advisory. Board-level engagement on MSB-sector questions: regulatory positioning, supervisory dialogue, M&A diligence involving MSBs, exits from existing MSB relationships, and entry into the sector.
What every engagement includes
Sector translation. Banks and MSBs often refer to the same artifacts by different names. A bank's “Monetary Instrument Log” is the MSB's “$3,000 Log.” A bank's “BSA Officer” may be the MSB's “Compliance Director,” or an outsourced role entirely. Every engagement includes the interpretive work that lets bank-side and MSB-side teams actually communicate.
Contextualizing transaction patterns. What looks alarming to a generalist BSA review may be routine in the MSB sector — and what looks routine may be the actual signal. We help institutions calibrate their judgment to what the sector actually does.
Discretion. Institutional engagements are confidential. Discussions, deliverables, and the existence of the engagement itself are treated accordingly.
Engagements begin with a briefing.
Institutions interested in scoping an engagement — for program review, design, referrals, rehabilitation, or strategic advisory — should request a confidential briefing.
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