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Money Transmitter License: Compliance Officer Requirement

Learn what regulators require from compliance officers for MTL applications, including qualifications, documentation, and when to hire full-time vs. fractional.

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Compliance officer reviewing money transmitter license application documents and AML policies at a modern fintech office desk

Regulators require every business applying for Money Transmitter Licenses (MTLs) to name a Compliance Officer. Early-stage startups can meet this requirement by hiring someone full-time or bringing in a fractional compliance lead until they scale.

What the Compliance Officer Actually Does

The Compliance Officer owns all regulatory controls and their responsibilities typically include:

  • Overseeing AML, KYC, and customer due-diligence programs. AML policy implementation is the biggest bucket of responsibility on their plate. 
  • Ensuring compliance with federal rules and state money-transmitter regulations
  • Maintaining and updating internal policies
  • Conducting internal audits and advising on risk management
  • Training staff and updating procedures when regulations change

Qualifications Regulators Expect

General finance or fintech experience isn’t enough. The Compliance Officer must have AML experience, and some states—like New York—expect at least five years of US AML experience. Certifications like CAMS are useful, but not required.

Fractional vs. Full-Time

Many early-stage startups start with a fractional compliance officer. However, as you expand into more states—especially the larger and stricter ones—you’ll need someone full-time and on payroll. Best practice is to have a full-time internal compliance lead in place before beginning any licensed activity so policies, especially AML, are implemented consistently.

Documentation Needed for MTL Applications

States typically ask for:

  • Full resume or CV
  • Copies of degrees and certifications
  • Background check and fingerprinting
  • A detailed write-up of compliance experience
  • An organizational chart showing reporting lines

Finding Strong Compliance Candidates

Good candidates can be sourced through:

  • Banking, fintech, and compliance job boards
  • Recruiters specializing in AML, risk, and financial services like HW3‍
  • Network at industry conferences or through compliance associations (e.g., ACAMS, ABA, CSBS)

Compensation Expectations

Pay varies by location, experience, and company size:

  • Entry-level roles: $65,000–$90,000‍
  • Experienced full-time officers: $100,000–$180,000+ (Higher end is indicative of salaries in NYC, SF, Seattle, etc)
  • Fractional/contract roles: $100–$250 per hour, depending on expertise

FAQs

Is a compliance officer required for every state money transmitter license?

Yes, regulators require every business applying for a money transmitter license to designate a compliance officer. This person is responsible for owning the company's regulatory controls and ensuring ongoing compliance with all applicable state and federal requirements.

Where can I find qualified compliance officer candidates for MTL applications?

Strong candidates can be found through banking, fintech, and compliance-specific job boards, as well as recruiters who specialize in AML, risk, and financial services. Industry conferences and compliance associations like ACAMS, ABA, and CSBS are also valuable networking resources.

What documentation is needed for a compliance officer on an MTL application?

State regulators typically require a full resume or CV, copies of degrees and certifications, background check and fingerprinting results, a detailed write-up of compliance experience, and an organizational chart showing the compliance officer's reporting lines within the company.

Can a startup use a fractional compliance officer for an MTL application?

Yes, early-stage startups often begin with a fractional compliance officer to meet regulatory requirements. However, as you expand into more states, especially larger or stricter jurisdictions, you will need a full-time compliance lead on payroll. Best practice is to have a full-time officer in place before beginning any licensed activity.

What qualifications do regulators require for a money transmitter compliance officer?

Regulators require compliance officers to have direct AML experience. General finance or fintech backgrounds are not sufficient. Some states have stricter requirements—New York, for example, expects at least five years of US AML experience. Certifications like CAMS are helpful but not mandatory.

What does a compliance officer do for a money transmitter license?

A compliance officer oversees all regulatory controls for a licensed money transmitter. Their responsibilities include managing AML, KYC, and customer due-diligence programs, ensuring compliance with federal and state money transmitter regulations, maintaining internal policies, conducting audits, advising on risk management, and training staff when regulations change.

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