Under a sponsorship model, you do not need a compliance officer (either part-time or full-time), as you are not taking custody of funds. The funds are essentially being ‘handled’ for you, on your behalf as per the agreed terms. So, strictly speaking, a compliance officer is NOT needed.
Whilst it certainly helps to have one (going forward when you expand your business and get your own licenses), to start out, you do not need one, as the onus of the transactions is not on you.
-  How to Start a Money Transfer Business? Compliance & Law Tip!
-  MSB Friendly Bank: Is Your Compliance Program Really The Best?
This page was last updated on February 28, 2023.