AML and Compliance Officer Services

Operators that move funds may face anti-money-laundering and countering-the-financing-of-terrorism (AML/CFT) requirements or commercial expectations from applicable law, regulators, banks, payment processors, or other partners. The exact duties depend on the business model and jurisdiction. BCA helps operators document the program, assign responsibility, implement controls, and maintain the operating evidence reviewers request.

Who this is for

These services are for operators whose legal, licensing, banking, payment, or risk requirements call for documented AML/CFT controls. That can include online and social gaming, sweepstakes and promotional-game operators, daily fantasy and skill-gaming platforms, and fintech and payments companies. Support may begin before launch, when a reviewer asks for a policy and clear program ownership, or after launch, when controls, evidence, reports, and exceptions must be maintained.

Scope depends on your model

Whether a federal AML program rule applies depends on what the operator is. Casinos and card clubs above the regulatory revenue threshold, money services businesses and money transmitters, and other defined financial institutions are directly covered. Many gaming, sweepstakes, and fintech platforms are not automatically covered by that federal rule, but they may still be required or asked to maintain AML/CFT-style controls because of state licensing, banking, payment-processor requirements, or their own risk profile. Part of our work is helping you determine which applies and build to it.

What an AML/CFT program needs

Regulators, banks, and processors look for the same core elements where a program is expected. BCA helps build or coordinate each part:

• A written AML/CFT policy customized to how your platform actually handles money and identity.
• Clear program ownership, including a designated compliance officer where the applicable requirements call for one.
• Internal controls and transaction monitoring, including customer identification, due diligence, risk assessment, sanctions and OFAC screening, and suspicious-activity monitoring.
• Ongoing staff training so the people running the platform know what to do.
• Independent review and testing to confirm the controls are working and to satisfy partners.

For a plain-English look at why payment processors and regulators expect these elements, and what to do when a processor asks who your compliance officer is, see our article Money In, Money Out: What Gaming and Fintech Operators Should Prepare Before a Processor Asks.

How BCA can help

Pre-launch policy and approval support

We draft and customize AML/CFT policies, help define program ownership, and support processor or regulator review. BCA can serve as your designated compliance officer under a retainer agreement that defines the role, its authority, and its reporting duties. The operator remains responsible for its program and approvals.

Ongoing compliance officer support

After go-live, BCA can provide separately scoped compliance support. Depending on the engagement, that may include defined compliance-officer duties, scheduled transaction-flow reviews, issue handling, reporting, policy maintenance, and coordination with the operator’s legal and technical teams. The written scope sets the hours, authority, deliverables, and escalation path.

Compliance review and technical certification

We conduct technical control reviews and readiness reviews of your KYC, geolocation, AML/CFT, and financial controls, covering both the software and the written procedures behind it. The review can conclude with a technical certification letter that documents what was tested and found, which payment providers and partners often request. A technical certification is a technical finding, not a legal opinion. Where a formal independent AML/CFT test is required, BCA coordinates with or prepares materials for an independent reviewer. Where BCA was not responsible for the function being tested, BCA can separately scope that independent review.

Coordinated Legal, Compliance, and Registered Agent Services

Gaming and fintech work can involve both legal and operational questions. Newman Law is of counsel to BCA. Legal opinions and counsel come from Newman Law through BCA to joint clients; Newman Law also provides Nevada registered-agent services. Alongside the operational, technical, and compliance support BCA provides, both sides of the engagement stay coordinated. Newman Law is a joint participant in the BCA Compliance Support & Audit service.

Why BCA and Mark Munger

This service line is built on hands-on experience, not theory. Mark Munger has more than 35 years in technology and regulated industries, with over two decades focused on gaming and fintech compliance. He has designed, built, and audited the KYC, AML, and geolocation systems that platforms rely on, and those systems have passed regulatory and payment-processor scrutiny across many U.S. states and international jurisdictions. His background includes reviewing data for anti-money-laundering purposes at the Bahamas Gaming Board and overseeing casino gaming reporting as Chief Information Officer for the Twenty-Nine Palms Band of Mission Indians, along with platform certifications carried out alongside independent testing labs such as Gaming Laboratories International and BMM Testlabs.

When an engagement requires licensed legal advice, Newman Law, of counsel to BCA, provides it through BCA. BCA is not a law firm and does not provide licensed tax advice; licensed tax work goes to independent tax professionals.

Start a conversation

Every platform handles money and identity a little differently, so engagements are scoped to your situation. Contact BCA to discuss where you are in your launch or operations and what level of support fits.

BCA provides business, operations, and compliance advisory services. The information BCA provides is intended to help operators make their own informed business decisions and does not constitute legal, accounting, or tax advice. When legal advice is needed, it comes from Newman Law, of counsel to BCA. Licensed accounting and tax work is handled with independent licensed professionals. Technical certifications reflect technical findings and do not constitute legal opinions.