The Problem
An Authorized Delegate model may be appropriate when a payment company needs to participate directly in a regulated U.S. money-transmission program without obtaining its own state licenses from the beginning.
The licensed Principal Money Services Business remains central to the program, while the delegate operates within the approved commercial, compliance, technical, and geographic scope.
The Solution: Build the Banking Structure Around the Transaction
Before approaching a bank, MSB, payment company, or settlement provider, we first determine:
- Who owns the funds?
- Where do the funds originate?
- What is the original currency?
- Is stablecoin involved?
- What is the commercial purpose?
- Which account needs to receive the money?
- Which payment rail is required?
- Who is the final beneficiary?
- What is the average and maximum transaction size?
- How much volume is expected each month?
- Are the funds the company's own money or customer money?
- Is licensing coverage required?
Only then do we determine the right account and provider structure.
What We Can Potentially Structure
| Business Requirement | Potential Infrastructure |
|---|---|
| Onboard approved customers | Authorized Delegate program |
| Participate in flow of funds | Principal MSB coverage |
| Use FBO/customer accounts | Program banking structure |
| Send domestic/international payments | Principal's approved rails |
| Integrate technology | API / dashboard / white-label where available |
| Scale states/corridors | Subject to principal's license footprint and approvals |
Not every business needs every component.
The objective is to build the smallest compliant structure that actually works.
Typical Flow of Funds
LICENSED PRINCIPAL MSB
|
| Authorized Delegate Agreement
v
BOLIVIA-LINKED PAYMENT COMPANY
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APPROVED CUSTOMERS
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REGULATED FLOW OF FUNDS
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v
BANK / FBO / PAYMENT RAILS
The precise flow will depend on the real ownership of funds, source of funds, jurisdictions, provider approvals, and whether the transaction involves the company's own money or money belonging to customers.
What the Delegate Relationship Changes
The business is no longer merely referring clients or providing software. It may become an approved participant in the regulated payment chain and must meet the principal's compliance and operational obligations.
Commercial Viability Matters
Licensed sponsorship has fixed costs. The model generally becomes more attractive when expected monthly volume is sufficient to support onboarding, compliance, banking, and program-management costs.
Compliance Responsibilities
The principal may require KYC/KYB procedures, transaction monitoring, suspicious-activity escalation, staff training, customer disclosures, reporting, audits, and ongoing oversight.
API vs. Authorized Delegate
An API-only model may keep the business outside the flow of funds. An Authorized Delegate model generally involves a more substantive regulated role. The right model depends on how the business actually handles money.
Compliance Is Part of the Product
A workable banking or payment solution is not simply an account number.
Depending on the structure, the provider may require:
- corporate formation documents;
- directors and UBO information;
- KYC/KYB;
- beneficial-owner verification;
- source-of-funds evidence;
- bank statements;
- invoices and purchase orders;
- counterparty details;
- sanctions screening;
- transaction monitoring;
- wallet screening where crypto is involved;
- expected monthly volume;
- average and maximum transaction size;
- beneficiary countries;
- customer types;
- transaction purpose;
- reconciliation procedures;
- and a complete flow-of-funds explanation.
The stronger the documentation, the easier it is for a regulated provider to understand the opportunity.
Own Funds vs. Customer Funds
This distinction is critical.
If a company is moving only its own money for its own commercial activity, the problem may primarily be one of banking, treasury, and cross-border settlement.
If the company:
- accepts money from customers;
- holds customer balances;
- transmits money to third parties;
- instructs payments on behalf of customers;
- operates a remittance or payment platform;
- or provides payment accounts to underlying users,
then a normal corporate account may not be sufficient.
The structure may require:
- a licensed payment provider;
- an FBO or pooled account;
- an Authorized Delegate relationship;
- Money Transmitter License coverage;
- or another regulated program structure.
A Typical Operational Roadmap
PHASE 1
Business + Flow-of-Funds Review
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PHASE 2
Account / Payment / Licensing Structure
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PHASE 3
Provider Selection
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PHASE 4
KYC / KYB / Compliance Package
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v
PHASE 5
Account / Program Configuration
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v
PHASE 6
Pilot Transactions
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v
PHASE 7
Scale Volumes / Add Corridors
Timelines vary substantially depending on the provider, business model, account type, licensing structure, ownership, transaction profile, and technology requirements.
Information We Need From You
Please provide:
- Company name
- Country of incorporation
- Website
- Principal / UBO LinkedIn profile
- Short description of the business
- Whether funds belong to the company or third parties
- Required account type
- Required payment rails
- Countries from which funds arrive
- Countries to which funds are sent
- Original funding currency
- Whether USDT or USDC is involved
- Monthly incoming volume
- Monthly outgoing volume
- Average transaction size
- Maximum expected transaction
- Main counterparties
- Main beneficiary countries
- Existing banking relationships
- Current banking or payment problem
- Expected growth over the next 6–12 months
- A flow-of-funds diagram, if available
If you do not have a diagram, describe the transaction in plain English.
We can convert it into one.
Frequently Asked Questions
Is approval guaranteed?
No.
All account, banking, payment, licensing, and provider approvals remain subject to the relevant institution's compliance, underwriting, risk, and onboarding requirements.
Does a U.S. account automatically allow me to operate a payment business?
No.
Banking access and money-transmission authority are separate issues.
Can the account be in the company's own name?
Potentially, depending on the provider and use case.
Can stablecoin be part of the transaction?
Potentially, where disclosed and approved by the relevant providers.
Can the structure support SWIFT or Fedwire?
Potentially, depending on the account and provider selected.
Can you help if I need a more complex payment program rather than one account?
Yes. Where appropriate, we can assess FBO, virtual-account, API, white-label, licensed-partner, or Authorized Delegate structures.
What We Actually Do
We are not simply selling an account.
We help structure the opportunity.
BUSINESS
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FLOW OF FUNDS
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RISK + REGULATORY ANALYSIS
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ACCOUNT REQUIREMENTS
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PAYMENT-RAIL REQUIREMENTS
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PROVIDER / BANK / MSB MATCHING
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PRELIMINARY FEASIBILITY
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INTRODUCTION
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KYC / KYB / DUE DILIGENCE
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ACCOUNT / PROGRAM APPROVAL
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IMPLEMENTATION
The objective is to avoid wasting months with providers that were never able to support the transaction in the first place.
Request an Authorized Delegate Assessment
Do not start by asking for a random account.
Start with the transaction.
Tell us:
Where does the money come from?
Who owns it?
How much moves each month?
What is the average transaction size?
Which currencies are involved?
Where does the money ultimately need to go?
Do you need named accounts, SWIFT, Fedwire, FBO infrastructure, stablecoin settlement, or licensing coverage?
We will review the flow and determine what account, banking provider, payment company, licensed intermediary, or settlement architecture may realistically support it.
Related Pages
- Bolivia Banking & Payments
- Named Accounts
- FBO Accounts
- MSB Banking
- Authorized Delegate / Agent Sponsorship
- Money Transmitter Licensing
- Cross-Border Payments
- SWIFT Payments
- U.S. Banking for Foreign Companies
- Stablecoin Settlement
Important: Availability, pricing, corridors, account structures, payment rails, and regulatory requirements are profile-specific and subject to third-party approval. Faisal Khan LLC provides advisory, structuring, and introductions; it is not a bank and does not hold client funds.
