Fintech compliance packages
Most fintech compliance starts with one of two questions: do I need an MTL, and is my KYC program defensible. These packages answer both.
Money Transmitter Analysis
State-by-state analysis of whether your fintech triggers money transmitter licensing in each U.S. jurisdiction. Includes a ranked roadmap.
- Federal definition analysis (BSA, FinCEN guidance)
- State-by-state MTL trigger analysis (50 states + DC)
- Agent-of-payee vs principal payment analysis
- Bank-partnership / sponsor-bank model analysis
- Stablecoin / crypto-MTL implications if applicable
- Ranked state-licensing roadmap with cost estimates
- Written memo, board-ready
KYC / AML Program Review
Review of your existing KYC and AML program against BSA / FinCEN standards. Identifies gaps before a regulator does.
- Customer Identification Program (CIP) review
- Customer Due Diligence (CDD) and EDD program audit
- Sanctions (OFAC) screening process review
- Suspicious Activity Report (SAR) filing posture
- Recordkeeping and BSA reporting compliance check
- Written gap memo with prioritized remediation list
Payments Contract Stack
Customer agreement, processor agreement, dispute / chargeback protocol, and bank-partnership framework for fintechs and payments-active SaaS.
- Customer payments terms tailored to your model
- Processor / sponsor-bank agreement markup template
- Chargeback and dispute protocol
- Reserve / hold language with state-law sensitivity
- Reg E / Reg Z disclosures where applicable
- Coordinated defined terms across all documents
Who this is for — and who it isn't
This is for you if:
- Fintech founders pre-launch through Series B
- SaaS companies adding payments or money-movement features
- Bank-partner / banking-as-a-service operators
- Crypto-adjacent companies needing MTL clarity
- Companies hitting first state-regulator inquiry letters
This isn't for you if:
- Federally chartered banks (specialty firm work)
- Investment advisors registered under the Advisers Act
- Securities-token offerings (use Securities Startup Counsel Hub)
- BSA enforcement / DOJ investigation defense (referred)
My approach
Fintech compliance is risk-mapping at scale: 50 states, federal regulators, and bank partners. Get the map drawn before you ship.
Structured intake
60-90 minute working session. Money flow, customer profile, fund custody, bank-partner relationships, and where you currently sit on licensing.
I run the analysis
Within 10-15 business days I deliver the MTL roadmap, the KYC/AML gap memo, or the payments contract stack — whichever package you ordered.
Execute the roadmap
You file MTL applications, fix the KYC gaps, or wire the contracts in. I support follow-up regulator questions for 30 days post-delivery, escalation to specialty firm if needed.
Recent client results
"Sergei’s MTL roadmap saved us from a six-figure compliance retrofit. We chose a sponsor-bank model instead of state-licensing in 23 states."— Fintech CEO saved $200K+ in licensing costs
"KYC review found three SAR-trigger workflows that weren’t documented. Closed before our state regulator inquiry."— Bank-partner SaaS founder
"Payments contract stack came back coordinated and consistent. Our processor signed without redlining the customer-side terms."— Embedded-finance founder
Why work with me
Sergei Tokmakov, Esq.
I have been a California-licensed business attorney since 2011, with deep work on payments, fintech licensing, and KYC/AML programs. I have helped fintechs map MTL exposure across all 50 states, run KYC program audits, and architect payments contract stacks for both startups and bank-partner programs.
The packages are flat-fee. You know what the analysis costs before it starts — which matters in fintech, where compliance work can otherwise be a black-hole hourly engagement.
Frequently asked questions
Do I need an MTL if I’m using a sponsor bank?
Often no — the agent-of-payee or sponsor-bank model can keep you out of MTL territory in many states. But not all. The MTL analysis package maps state-by-state whether your specific structure triggers licensing.
What’s the difference between KYC and CDD?
KYC (Know Your Customer) is the umbrella term. CIP (Customer Identification Program) is the specific BSA-required process for verifying customer identity. CDD (Customer Due Diligence) is the ongoing risk-rating and monitoring layer. The KYC review covers all three.
Do you handle MTL applications themselves?
I produce the analysis and roadmap. The applications themselves are typically handled by specialty fintech licensing firms or by the company’s in-house compliance team using the roadmap as the playbook. I refer to or co-counsel with the right firm if you need application support.
What about BSA/AML examination support?
Initial response to a state or FinCEN inquiry can be handled inside the engagement at $240/hour. Formal enforcement actions or DOJ-driven matters get referred to specialty defense firms.
Do you handle Reg E or Reg Z disclosures?
Yes — the Payments Contract Stack package includes Reg E (consumer EFT) and Reg Z (TILA / open-end credit) disclosures where applicable to your product.
What about crypto / stablecoin MTL?
Crypto-MTL exposure is highly state-dependent and changes frequently. The MTL analysis package covers crypto-specific triggers in each state where your users sit, including the New York BitLicense and California DFPI guidance.
Related resources I've written
Securities Startup Counsel
For raise-side legal work and securities posture.
SaaS Legal Package
For SaaS-only documents (non-fintech).
Stripe Frozen Funds Lawyer
When a payment processor holds your business funds.
Contract Review
Single-document review starting at $349.
Fractional CLO
Ongoing fintech legal work across compliance, contracts, and governance.
Map the fintech compliance landscape before you ship.
MTL analysis $3,500. KYC/AML review $2,500. Payments contract stack $3,000. Pick the one that matches the question you’re trying to answer.