We run it. You govern it.
Fractional compliance leadership and operated compliance functions for fintechs that need execution capacity, not another plan. Alert review, investigations, filings, testing, and reporting, run by our team on systems built to produce a record.
Most clients arrive here after a readiness engagement, once they know what needs to run and how well.
We Execute. You Govern.
Outsourcing compliance operations doesn't mean losing control. We handle the daily execution: monitoring, investigating, filing, testing. Your leadership maintains strategic oversight and regulatory accountability.
Bright Sea Executes
- Daily alert review and investigation
- SAR drafting and filing
- Policy and procedure maintenance
- Board and partner reporting
- Transaction monitoring operations
- Examination preparation
You Govern
- Strategic oversight
- Regulatory accountability
- Final decision authority
Outsourcing compliance operations does not transfer regulatory accountability, and any firm that implies otherwise is describing something that does not exist. Client leadership retains ultimate responsibility for program effectiveness.
Where You Are Determines How We Help
You need a program before your first transaction.
We design and build your compliance program from scratch: BSA/AML program, policies, monitoring rules, reporting infrastructure. Examination-ready before day one.
Your program can't keep up with volume.
Your existing program worked at lower volume but it's breaking under growth. We add operational capacity, automate workflows, and strengthen controls without rebuilding from scratch.
The bank is asking questions you can't answer.
Your sponsor bank is tightening oversight, an exam is coming, or your current program has gaps. We step in, assess the situation, and execute the remediation.
Partner, or charter?
More than thirty fintechs have been through the federal bank charter process in 2026. Circle, Mercury, Upstart, and Stripe-owned Bridge among them, and all four cleared: Circle with final approval in July, the other three conditionally. The OCC finalized its national trust bank activities rule on 27 February 2026, effective 1 April. And the Federal Reserve has proposed limited payment accounts that would give qualifying nonbanks direct access to Fedwire, FedNow, and the National Settlement Service.
Every sponsor-bank relationship now has a question underneath it that did not exist two years ago: is partnering still the right structure, or are you building toward your own?
We do not have a view on which answer is right for you. We have a view on how it gets decided. When the OCC denied bunq's application on 4 August 2026, it did not turn on any one thing. The decision cites capital, management experience, profitability projections, risk management in the business plan, and organizers who "lacked sufficient background and experience in banking." The path is open and it is graded, and it is graded on whether what you are proposing is something a regulator can supervise. Compliance maturity is part of that, not the whole of it. Whichever way you go, most of the work is the work your sponsor bank is already testing.
Core Competencies
Compliance operations that hold up under scrutiny.
Whether you're building from scratch, scaling operations, or responding to pressure: we execute, you govern.
Or email directly: contact@brightseaadvisors.com