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FAQ: Risk & Compliance

  1. What type of financial institution will you introduce us to?
  2. I learnt the concept of FBO/ Omnibus account/ Pooled account, so considering our models, how can we charge our service fee (let’s say 2% of the transaction amount) on behalf of our merchants (since we cannot touch the fund)?
  3. If we opt for API only, will KYC/AML service continue to be provided by the PLH? Please confirm.
  4. All we need is our CEO, a compliance officer, and an office located in the EU (possible). Am I correct? Are the compliance officer + the office required to be based in the license holder’s country?
  5. Will the license holder assist us with the process, or do we have to consult some law firm, or your team? If we have to seek consultation, what is the additional cost of it (a rough number is fine)?
  6. What are the Licensed MSB options we will affiliate with? (The ones who own the remittance platform, Compliance and Card/ACH Payment Gateway)
  7. Is it required to register our company with FinCen? Despite not touching the funds, we have no intention of opening an account in the US, our tax address is in Ecuador.
  8. From what we understand and know, there should be a person/company in the US who provides services on legal compliance issues. Do you include this service with the indicated monthly price?
  9. Because it is the fastest way in terms of cost/benefit/time, you make contact with a Bank or an MSB company, which allows us to operate a digital remittance platform? And, do you also provide the legal compliance service?
  10. Does Faisal Khan offer compliance management? I’m not sure how this works in America, but in the United Kingdom, sometimes the license consulting company is also the Chief Compliance Officer.
  11. Our software is currently undergoing security testing, do we need to contract any other testing or quality assurance firms to meet the obligations of a sponsorship agreement?
  12. Does Faisal Khan LLC create custom AML policies?
  13. As a sponsored party which parties do we share our customers’ KYC information with, if any?
  14. Who will be in charge of ID verification process or KYC process? Will it be me or someone else?
  15. Who is responsible for anti-money laundering?
  16. What is the timeline before we can go live?
  17. Does the Bank Account Verification also include ID verification?
  18. Do we need to hire a full-time compliance officer?
  19. What is a KYC and is there an API for it? Is it for the beneficiary?
  20. Once I sign the referral agreement, what should I expect next?

This page was last updated on January 18, 2023.