A BSA/AML officer your bank partner can call.

It can, but it depends on who is asking. Whether a fractional officer can hold the designated seat turns on your regulator, your license conditions and your program agreement with your bank partner. Some accept a fractional officer with the right governance; others expect an employee, or a full-time officer once the program reaches a certain size. FinCEN does not certify or approve BSA officers, so what matters is the authority, independence and resources behind the seat.

We work through the question with you before the seat is scoped. Ethixera Advisory is not a law firm, so the legal reading of your license conditions stays with your counsel. Where a fractional seat fits, it comes with a board resolution, a written delegation of authority, documented hours and backup coverage.

It depends on who holds the filing obligation. If your company is itself required to file, as a money transmitter generally is, the decision to file or not to file sits with the named officer under the delegation of authority, made on the facts and documented without sign-off from sales, product or revenue owners. If you operate under a sponsor bank and the bank holds the filing obligation, the bank typically makes the final filing decision; the officer investigates, documents the case and sends the referral on the timeline your program agreement sets.

Either way, SAR confidentiality rules apply to what can be shared and with whom.

First, the documents that set up the seat: the board resolution, the delegation of authority, the hours and coverage commitment, the backup arrangement and the conflicts disclosure.

Then a regular reporting pack on the cadence your program agreement sets, usually covering alert and case volumes and aging, escalations and referrals, risk assessment changes, policy updates, training, testing results, and open issues with remediation dates. And a direct line to the officer.

What the bank can see about specific suspicious activity reports is governed by SAR confidentiality rules and your program agreement, and the reporting pack is built around both. For the wider diligence file, see sponsor bank readiness.

It depends on your products, volume and risk, not on a standard package. A pre-launch or low-volume program needs less time than a live program with its own alert queue, SAR decisions and a bank partner asking for monthly reporting. We size the hours during scoping, match them to the Foundational, Active Leadership or Enhanced model on our Fractional CCO page, write them into the engagement, and review them at least once a year or whenever volume, products or findings change.

That is a good outcome, and the engagement plans for it from the start. The signals are usually alert and case volumes that need daily attention, a bank partner or regulator asking for a full-time officer, or a new license or product.

We help define the full-time role, mentor the person you hire into it, and run a documented handover so the designation passes from one named officer to the next without a gap, with your board and bank partner told in advance. Ethixera can stay on in an advisory or fractional CCO role afterward if that helps.