We write the compliance programs regulated fintechs run on, operate them day to day, and build the payment infrastructure underneath. When a sponsor bank asks for evidence, it already exists.
Led by an attorney who has built compliance programs and the systems underneath them at Citi, Mastercard, UnionPay International, and TikTok.
Policies, procedures, and risk assessments. BSA/AML program design and build, written to match what the platform actually does.
KYC/KYB, sanctions screening, transaction monitoring, and an immutable decision record, built into the payment flow rather than beside it.
Fractional CCO, BSA Officer, and CTO coverage. Alert review, investigations, filings, board and partner reporting.
Sponsor-bank diligence and US market entry. Also diligence in the other directions: on your vendors and counterparties, on your own customers, and support when an investor or acquirer examines your compliance posture.
A program arrives differently when the bank already knows who is running the compliance function. We work with sponsor banks, processors, and BIN sponsors regularly, we make introductions where they make sense, and we help you select and implement identity, screening, and monitoring vendors. We are not a referral business and we take no fees from banks, processors, or vendors.
Somebody else holds a decision over your business.
A sponsor bank, a processor, a regulator, an acquirer. Eventually each one says the same thing: show me.
Most fintechs cannot show. They can explain, they can send a policy, and they can spend three weeks assembling something by hand. That gap between explaining and showing is where accounts get exited.
The FDIC proposed a custodial recordkeeping rule in October 2024: beneficial-owner records, direct bank access, independent validation, an officer-signed annual certification. It was never finalized. Banks wrote its substance into their partnership agreements anyway. The rule never passed. Your bank adopted it anyway.
Your bank is asking for things it never asked for before, and you are answering from memory.
What is written down and what actually happens diverged somewhere around your third product launch.
Producing the last ninety days of decisions is a project, not a query.
A processor, a bank, or a US partner asked for documentation you have never had to hand over.
You added people to a problem that needed engineering, and it is still not keeping up.
The person who held the program in their head is gone, and nothing is written down at the level a reviewer needs.
Both finish before your review does. Both end with a document your leadership team can act on.
30 days
For fintechs facing a review, a renewal, a findings letter, or a new banking partner. We map what your counterparty will ask, test whether you can answer it today, and sequence the fixes by what they see first.
See what's included60 days
For international fintechs and payment companies entering or scaling into the US. We map your flow of funds, identify what US counterparties will require of your model, and scope the program before you build the wrong thing.
See what's includedMost firms work in one of these. The reviews that decide your future test all three at once.
Onboarding flows, payment logic, integrations, dashboards. The parts of the product where compliance decisions actually get made.
Approval states, monitoring rules, permissions, audit trails. The logic that governs those decisions, embedded in the system rather than described beside it.
Alert review, investigations, filings, reporting, examination support. The daily execution that keeps the record continuous instead of retrospective.
When the three are connected, evidence is a query.
When they are not, it is a project.
Bright Sea builds payout infrastructure with compliance inside the transaction layer rather than bolted beside it: onboarding, screening, monitoring, and a decision record produced by the system rather than assembled afterward. We have taken one from architecture through to sponsor-bank alignment and into production. That is how we know what these systems cost to build, and what a reviewer finds when they look inside one.
At onboarding, with the decision record retained
On every payout
With rules governed by compliance, not engineering
Covering every decision and every change
Linking transactions, devices, and risk scoring to one customer record
That generate board and examination reporting without manual assembly
Across US and international flows, came to us when its sponsor bank changed what it required. The diligence and contract review processes it had were built for the previous standard and no longer matched what the bank was asking. We rebuilt both. The platform runs them today against the bank's current requirements.
Engaged us to rebuild its compliance technology and the processes around it, so that what the platform did and what its program said matched. We led the build, embedded as its compliance and technology leadership, and aligned both to the bank's requirements. The platform is entering production.
We do not publish client names, approval rates, or regulatory outcomes. We do not guarantee bank access, licensing results, or regulatory decisions. What we deliver is that when the questions come, the answers already exist.
We work in categories where scrutiny is highest, sponsor-bank tolerance is lowest, and the vendors who claim to serve everyone quietly decline the engagement.
Both readiness engagements are fixed in scope and fixed in duration. They end with a document, a sequence, and a conversation with your leadership team.
Direct: kevin@brightseaadvisors.com