Know what you are buying before the term sheet.
Compliance due diligence on fintech and regulated targets before you commit capital, and compliance leadership for PE-backed and venture-backed portfolio companies after close.
Compliance Infrastructure Is Capital Infrastructure
A fintech's revenue runs on permissions: a sponsor bank that keeps the account open, licenses that let it move money, and a BSA/AML program its bank partner and examiners accept. Lose one and growth can stall.
Compliance infrastructure is capital infrastructure, so it belongs in diligence beside the financial model. The question usually arrives at one of four moments:
- A term sheet on a fintech target
- A close that triggers change-of-control filings
- A portfolio company with an open bank-partner or exam finding
- A portfolio company that has outgrown part-time compliance
From Term Sheet to Portfolio Oversight
Pre-Investment Compliance Diligence
We review who owns compliance, the BSA/AML and sanctions program as written and as run, testing and exam history, and sponsor bank standing. Findings are rated by severity and timed to inform terms.
Sponsor bank readinessLicensing Inventory
We map the licenses and registrations the target holds, the ones its business model needs, and the change-of-control filings your stake may trigger, against the deal timeline.
Money transmitter licensingPost-Close Integration
We turn diligence findings into a remediation plan with owners and dates, and build anti-corruption controls into portfolio companies operating in African markets.
FCPA and third-party anti-corruption diligencePortfolio-Company Fractional CCO
One accountable compliance lead for the portfolio company, reporting to its board and serving as liaison to its bank partner and regulators.
Fractional CCO servicesDiligence Tests the Program as Run
A policy binder shows what a target intends. Testing shows what it does. We sample customer, alert and partner files the way a bank validation team does.
Engagements are led by founder Victor B. George, JD. Our regulator-facing work includes direct engagement with FinCEN, state banking departments, FDIC and OCC exam teams and the DOJ, plus Big Four and national-firm validation work.
Top 10 U.S. Financial Institution
Directed BSA/AML testing and MRA validation across a multi-year remediation program. Managed quality assurance across the KYC customer file refresh program evaluating CDD/EDD standards.
Questions we hear
What does compliance diligence on a fintech cover?
It covers who owns compliance and how independent they are, the BSA/AML and sanctions program as written and as run, the license inventory, sponsor bank and partner relationships including open findings, and testing and exam history. We test samples, not just policies, and rate findings by severity.
Can you stay on as fractional CCO after close?
Yes. We can lead the portfolio company's compliance program under our Foundational, Active Leadership or Enhanced model, drive diligence findings to closure and report to its board. See fractional CCO services.
How do you handle a target with an open bank-partner finding?
We read the finding and the target's response, test whether remediation is on track, and estimate what closing it takes in people, time and evidence. That helps you and your counsel judge whether it is a price issue, a closing condition or a post-close workstream. See sponsor bank readiness.
How long does compliance diligence take?
It depends on the target's size, licenses, bank partners and data room. Every engagement starts with a discovery call, where we scope the work to your deal timeline so findings can still inform terms.
Do you cover anti-corruption risk in African or emerging-market targets?
Yes, with a focus on African markets. Victor has led anti-corruption programs under DOJ oversight. Our diligence looks at government touchpoints, third parties and what they are paid, and whether the program runs as written. Ethixera Advisory is not a law firm and does not provide legal advice. Legal conclusions stay with your counsel, and we coordinate with in-country counsel. See FCPA and third-party anti-corruption diligence.
Opening diligence on a target?
Tell us about the target, the deal timeline and what concerns you. We will tell you what compliance diligence should cover and how we would scope it.