A Practical Compliance Framework

For FinTechs, banks, and financial institutions operating in today’s rapidly evolving financial ecosystem, compliance isn’t just a requirement—it’s a business necessity. Whether you’re a FinTech working with a sponsor bank, a traditional bank, or a Banking-as-a-Service (BaaS) provider, your compliance framework needs to be robust, adaptable, and aligned with regulatory expectations.

At Key Compliance Group, we’ve spent years helping financial institutions navigate the complex world of regulatory compliance. The reality is that compliance missteps can lead to regulatory scrutiny, reputational damage, and financial losses. The key to avoiding those pitfalls? A structured, risk-based compliance program that not only meets regulatory requirements but also enhances operational efficiency and customer trust.

Below is a comprehensive compliance framework designed to help stay ahead of evolving regulations while fostering sustainable growth.

Anti-money laundering (AML) and financial crime risk management are non-negotiable for financial institutions. Whether you’re handling payments, deposits, or lending, BSA/AML compliance should be woven into your risk strategy.

Core Policies:

• BSA/AML & Sanctions Compliance Policy – Covers Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Suspicious Activity Reporting (SARs), and OFAC screening.
• Transaction Monitoring & Fraud Prevention Policy – Defines fraud red flags, AI-driven monitoring, and case management workflows.
• High-Risk Customer & Enhanced Due Diligence (EDD) Policy – Outlines requirements for high-risk clients, politically exposed persons (PEPs), and cross-border transactions.

With increasing regulatory focus on data security, customer privacy, and cyber threats, compliance programs must prioritize GLBA, CCPA, GDPR, and NYDFS cybersecurity requirements.

Core Policies:

• Privacy & Data Protection Policy – Ensures compliance with GLBA, CCPA, and GDPR for handling customer data.
• Cybersecurity Risk Management Policy – Covers security controls, vendor risk management, and incident response.
• Third-Party Risk Management Policy – Defines vendor oversight and regulatory expectations for outsourcing compliance.

If your business involves lending or Buy Now, Pay Later (BNPL), compliance with TILA, ECOA, FCRA, and CRA is a must.

Core Policies:

• Truth in Lending Act (TILA) Compliance Policy – Covers finance charge disclosures and APR calculations.
• Fair Lending & ECOA/Reg B Compliance Policy – Ensures unbiased lending practices.
• Loan Servicing & Collections Compliance Policy – Defines debt servicing and collections under FDCPA and RESPA.

Strong documentation ensures compliance with federal banking laws and simplifies regulatory exams.

Core Policies:

• Regulatory Record Retention & Documentation Policy – Outlines data retention periods for SARs, consumer complaints, and lending records.
• Regulatory & Sponsor Bank Reporting Policy – Covers required reporting, including SARs, CTRs, and UDAAP audits.