Fractional Chief Compliance Officer
Senior compliance leadership on a fractional basis. The governance, regulatory fluency, and institutional credibility your organization needs without a full-time executive hire.
Senior Leadership, Scoped to Your Needs
Not every organization needs a full-time Chief Compliance Officer. But every organization under regulatory oversight needs compliance leadership that regulators, boards, and partners take seriously.
Our Fractional CCO service provides senior compliance leadership on a part-time or project basis. You get the governance architecture, regulatory fluency, and institutional credibility of an experienced compliance executive without the overhead of a full-time hire.
Our principal has served in compliance leadership roles across Top 10 U.S. banks, Big 4 advisory firms, and regulated financial institutions. We bring that depth to your organization on the schedule your budget and regulatory environment require.
Choose the Model That Fits
Foundational
Monthly compliance oversight, quarterly board reporting, and annual risk assessment. Designed for organizations with a stable compliance environment that need senior governance presence.
Active Leadership
Weekly compliance engagement, monthly board reporting, examination readiness, and ongoing regulatory liaison. For organizations in active regulatory environments or building compliance maturity.
Enhanced
Embedded compliance leadership with daily or near-daily engagement. For organizations under enforcement action, undergoing rapid growth, or in the midst of significant regulatory change.
Scope, Assess, Lead, Report
Whichever model you choose, the engagement follows the same four stages.
- 01
Scope
A discovery call, then a written scope: the seat we take, the engagement model, who we report to, and what stays with your team.
- 02
Assess
A compliance risk assessment sized to your products, payment flows and licenses, and a gap review of the program your bank partner and regulators will read.
- 03
Lead
We run the program with your team: policies and procedures, monitoring oversight, examination readiness, and the working relationship with your bank partner.
- 04
Report
Regular reporting to your board and bank partner, a fresh risk assessment as products and volume change, and a move between models when your exposure shifts.
One Accountable Lead, in the Seat You Need
Some companies need senior leadership across the whole compliance program. Others also need a named BSA/AML officer that their bank partner and regulators can hold to account. We set out which seat we are taking, and on what terms, in writing before the work starts.
Fractional CCO
Senior leadership across the compliance program: governance, board and committee reporting, examination liaison, and the working relationship with your bank partner, investors and regulators.
Named BSA/AML officer of record
Where your bank partner or regulator expects a designated officer, Ethixera can take on that seat on defined terms: a written delegation of authority, independence over SAR decisions, and direct reporting to your board and bank partner.
What stays with your company
Ownership of the program, board oversight, and the people and budget to run it stay with you. A fractional seat works when the company supports it, and the engagement terms say so plainly.
Whether a fractional officer can hold the designated seat depends on your regulator, your license conditions and your bank partner. We work through that question with you before the seat is scoped. For a market-by-market view, see which U.S. rules require a designated compliance officer.
Built for Venture-Backed Fintech and Payments Founders
Founders usually meet compliance from three directions at once: a sponsor bank that wants evidence, a product roadmap that will not wait, and investors who will ask the same questions the bank asked. A fractional CCO gives you one accountable compliance lead who answers all three consistently.
We work inside your operating rhythm. Compliance review sits in product planning and launch decisions, not after them, so a new feature or payment rail reaches your bank partner with a risk assessment and controls already in place.
The goal is a compliance function your company owns. We write the program with your team, mentor the people you hire into it, and move between engagement models as your regulatory exposure changes.
Ethixera Advisory is not a law firm. We work alongside your outside counsel, who handles the legal questions.
For the full founder view, from the first bank conversation to the next raise, see compliance for venture-backed fintech founders and sponsor bank readiness.
When Founders Bring Us In
The signal that it is time for fractional compliance leadership is usually specific. Start where you are.
An exam notice
An examiner has scheduled a visit, or your bank partner's regulator is asking about its fintech programs. Exam readiness needs an accountable lead and evidence that holds up.
A sponsor bank request or audit
Your bank partner has sent a diligence request, scheduled an audit or raised a finding. The response needs to come from someone who owns the program.
Sponsor bank readinessA raise and investor diligence
A round is coming, and investors will ask what your bank partner asks: who owns compliance, what the program covers and what the last test found.
A first money transmitter license
A first state license or FinCEN MSB registration typically calls for a BSA/AML program, control-person disclosures and someone accountable for compliance.
Money transmitter licensingA new product or payment rail
Cards, cross-border payouts, digital assets or a new payment rail change your risk profile. Your bank partner will expect a risk assessment and controls before launch.
An enforcement action or consent order
An enforcement action, consent order or bank-partner remediation plan has landed. The Enhanced model puts embedded leadership in place while remediation runs.
Consent order and MRA remediationThe Experience Behind the Engagement
Fractional leadership is only as credible as the experience behind it. Victor B. George, JD, Ethixera's founder and principal, brings 15+ years across Big 4 advisory firms, Fortune 500 financial institutions, and regulated healthcare companies. He has led consent order remediation programs, enterprise risk assessments, AML/BSA validations, and anti-corruption programs under DOJ oversight.
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 25 U.S. Banking Institution
Conducted comprehensive 2LOD compliance testing and transactional reviews across the Banking division. Identified deficiencies and recommended actionable remediation strategies.
Deciding Which Compliance Seat You Need
Two pieces for founders and boards weighing fractional leadership against a full-time hire or a named officer.
The fractional CCO advantage: when it works, when it does not
When a fractional compliance lead is the right model for a company, and when a full-time hire is.
The fractional CCO advantageFractional CCO or BSA officer of record: which seat your bank partner is asking for
How to tell whether your bank partner wants senior compliance leadership, a named BSA/AML officer of record, or both.
Fractional CCO or BSA officer of recordQuestions we hear
When should a fintech bring in a fractional CCO?
Ideally before your first sponsor bank diligence request, not after it: when you are selecting a bank partner, preparing a first license, raising a round, or launching a product that changes your risk profile. It is also the right call when an exam notice, audit finding or enforcement action arrives and there is no senior compliance lead in place. The Foundational, Active Leadership and Enhanced models let you match the engagement to that moment.
What does a sponsor bank ask for in diligence?
Requests typically cover ownership and control, your license inventory, your compliance program documents (BSA/AML and sanctions policies, risk assessment, customer due diligence and monitoring procedures), diligence files on your own partners and vendors, and your most recent testing results. Many banks now also test whether compliance is independent of the business, whether they can see customer-ledger and transaction data, whether your BSA/AML capability matches your volume, and how you handle complaints. A fractional CCO can own that pack and keep it current. See sponsor bank readiness.
Can you act as our named compliance officer?
Yes, where your regulator, license conditions and bank partner allow a fractional officer to hold the seat. Ethixera can take on a named compliance officer or BSA/AML officer role on defined terms: a written delegation of authority, independence over SAR decisions, and reporting lines to your board and bank partner, all set out in the engagement. We confirm the seat can be held fractionally before it is scoped. The details are on our named BSA/AML officer of record page.
What does a first money transmitter license take?
More than an application form. State regulators generally look for a BSA/AML program, a surety bond, minimum net worth and permissible investment requirements, audited financial statements, a business plan, and background and financial disclosures for control persons, usually filed through NMLS. Money transmitters generally must also register with FinCEN as a money services business. Requirements and timelines vary by state, so the order in which you file matters. We prepare the compliance side of the application and work alongside your counsel on the legal questions. See money transmitter licensing.
How do you work with our outside counsel?
As one team with a clear split. Ethixera Advisory is not a law firm and does not provide legal advice. We build and run the compliance program: the risk assessment, policies and procedures, monitoring, testing, board reporting and the day-to-day relationship with your bank partner. Your outside counsel handles legal interpretation, licensing opinions and anything that needs privilege. We share what your counsel needs, flag questions that need a legal view, and keep both workstreams aligned.
Is Ethixera a law firm?
No. Ethixera Advisory is a compliance advisory firm, not a law firm, and does not provide legal advice. We work alongside your counsel, who remains responsible for legal opinions and legal representation.
Need Compliance Leadership Without a Full-Time Hire?
Let us scope a Fractional CCO engagement that matches your regulatory environment, budget, and growth trajectory.