AML compliance for smaller, non-bank financial firms – how are you all handling agent networks?
Hey everyone, I'm working with a relatively small firm that provides payment services, and we're expanding our agent network in a few developing markets. My main concern right now is the AML compliance piece, specifically around due diligence for these agents and then ongoing monitoring of their sub-agent activity. We're not a bank, so our resources aren't unlimited, but obviously, the regulatory heat is still there.
Are larger players' robust systems even feasible for a smaller shop? We're trying to automate where we can, but a lot of this still feels very manual. For those of you in similar boats, what's your practical approach to ensuring these agent networks aren't inadvertently exposing you to undue money laundering risks, especially when dealing with high volumes of smaller transactions?
This sounds like a significant lift for a smaller operation. Are you exploring any third-party solutions for agent due diligence and monitoring, or trying to build out a system internally?