We have covered the unique disadvantages that plague fintech, when it comes to having effective AML compliance; there will always be inexperienced compliance officers, and a corporate culture that emphasizes growth and thereby profitability over good compliance gatekeeping procedures, so a workaround is not only good business, it is necessary, if sponsor banks are to protect themselves from money laundering problems that originate at their fintech partners.
It is time for sponsor bank partners to offer an effective and timely solution. We humbly suggest a two-part response:
(1) Set up a dedicated telephone line, and email address, within the sponsor bank's compliance department, whose sole mission is to respond to real-time AML or CFT queries from fintech frontline compliance officers. Incoming queries are to have immediate, priority attention, forthwith, with proper alerts to warn sponsor bank compliance that one exists. This way, they will get answered first. call it a "hotline" to solve problems.
(2) Arrange a specific contact act at the outside firm which provided the software products that the sponsor bank delivered to the fintech, to assist with compliance, so that technical issues, or the need for additional platforms, can be addressed when they arise.
This way, fintech compliance officers have a direct contact with someone experienced at frontline AML, who can answer specific questions about a problem, as well as software providers who can supply technical support, or suggest new products, where issues arise. Short of placing their own staff inside fintechs, we believe this is a way to answering the questions of active, frontline fintech compliance officers, on the spot, and without delay.
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