Confidential by defaultEstablished 201072 Jurisdictions

Would our company be an agent of the sponsor? I’ve read a lot of jargon about the agent relationship; could you please elaborate on this a bit.

The question in full

Would our company be an agent of the sponsor? is at the heart of every fintech's legal structure. While 'Agent' is a general term used in common law, 'Authorized Delegate (AD)' is the specific regulatory designation used by FinCEN and State Regulators (like the NYDFS or California DFPI). Under this model, your company operates as an extension of the Principal License Holder's regulatory authority.

Answer

You can be, it depends on the sponsoring organization and how they would like to structure your deal. Ideally, everyone wants simplex to complex. Agent relationships are mid-way complex.

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Faisal KhanAnswered 07/Aug/2026
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Page Last Updated: 07/Aug/2026 (7488383)