AML-BSA Compliance for Oregon Businesses
This page summarizes public data on Oregon's money services businesses, mortgage lenders and investment advisers, the FinCEN orders that have covered Oregon counties, and the state agency that licenses money transmitters.
Oregon AML Regulatory Context
195 FinCEN-registered MSBs list a principal address in Oregon, and 185 of them operate in three or fewer states, the 30th-highest count of any state; the largest groups are in Portland, Hillsboro, Beaverton.
What Oregon Businesses Need to Know About BSA/AML Compliance
The Bank Secrecy Act (BSA) applies to every regulated financial business in Oregon. Size does not matter. FinCEN (Financial Crimes Enforcement Network) expects covered businesses to maintain a risk-based AML program. Common program elements include:
- A written AML program
- Ongoing employee training
- A documented BSA risk assessment
- Independent testing or review where required
- Customer due diligence procedures where applicable
If you miss any of these, the penalties are serious. Willful BSA violations can bring civil penalties of up to $286,184 each, and some violations count separately for each day they continue. Negligent violations can bring up to $1,430 each, or $111,308 for a pattern of negligence. Criminal penalties may also apply. (31 U.S.C. 5321; 31 CFR 1010.821, as adjusted January 2025.) You could also lose your license. And the reputational damage is hard to fix.
In Oregon, you answer to two regulators: FinCEN at the federal level and Oregon Division of Financial Regulation (ODFR) at the state level. Each has its own requirements. The Oregon Division of Financial Regulation licenses money transmitters in Oregon. Licensees also register with FinCEN, and the IRS examines MSBs for federal BSA compliance on FinCEN's behalf. This means Oregon businesses must satisfy both sets of rules, not just one.
Three common gaps in AML programs:
- Old AML policy manuals. They don't reflect current FinCEN rules or the business's actual products and services.
- Missing training records. Employees completed the training, but nobody kept the certificates for the audit file.
- Fake independent reviews. The BSA officer reviewed their own program. That doesn't count, independence is required.
Any one of these gaps can trigger a regulatory finding during an examination.
Soflo Consulting provides AML/BSA risk assessment support and a complete AML program for Oregon businesses, all online. No traditional consulting engagement. No proposals. No waiting.
Our platform supports the core elements of an AML program. You get written policies, a BSA risk assessment, employee training with certificates, an independent program review where required, and customer due diligence procedures.
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Oregon Compliance Snapshot
- Federal RegulatorFinCEN (Financial Crimes Enforcement Network)
- State RegulatorOregon Division of Financial Regulation (ODFR)
- Training FrequencyOngoing (annual cycle common)
- Risk AssessmentUpdate per risk profile & requirements
- Independent ReviewWhere required, independent party
- Cities Covered1 Oregon markets
Key Penalty Risk
Willful BSA violations can bring civil penalties of up to $286,184 each, and some violations count separately for each day they continue. Negligent violations can bring up to $1,430 each, or $111,308 for a pattern of negligence. Criminal penalties may also apply. (31 U.S.C. 5321; 31 CFR 1010.821, as adjusted January 2025.) Oregon state regulators may impose additional fines and license revocation.
AML Compliance in Every Oregon Market
Select your city for a dedicated AML-BSA compliance guide, local regulatory context, and instant-access training programs.
Top AML-Risk Industries in Oregon
Each industry operating in Oregon faces a distinct AML risk profile shaped by its customer base, transaction types, and geographic exposure. Money services businesses face heightened scrutiny from FinCEN due to cash-intensive operations. Mortgage lenders must comply with FinCEN's non-bank residential mortgage lender and originator (RMLO) rules. Real estate professionals and title companies are subject to Geographic Targeting Orders (GTOs) in high-risk markets. Soflo's industry-specific training and documentation address the exact risk factors regulators examine in each sector.
Oregon by the Numbers
195 FinCEN-registered MSBs
195 money services businesses registered with FinCEN list a principal address in Oregon. 185 of them register to operate in three or fewer states, the 30th-highest count of any state. Source: FinCEN MSB Registrant Search, Sep 29, 2026.
38 HMDA mortgage lenders
38 lenders headquartered in Oregon filed 2025 HMDA data. Source: FFIEC HMDA 2025 filers.
165 SEC-registered advisers
165 SEC-registered investment advisers list a main office in Oregon. Source: SEC adviser registrations, Sep 2026.
State Regulator
Oregon Division of Financial Regulation(ODFR)
The Oregon Division of Financial Regulation licenses money transmitters in Oregon. Licensees also register with FinCEN, and the IRS examines MSBs for federal BSA compliance on FinCEN's behalf.
FinCEN Orders and Designations in Oregon
None of FinCEN's three most recent Geographic Targeting Orders covered Oregon counties.
Where Oregon MSBs Are Based
- 1.Portland19
- 2.Hillsboro15
- 3.Beaverton11
- 4.Woodburn10
- 5.Salem10
- 6.Mcminnville10
- 7.Hermiston9
- 8.Medford8
- 9.Cornelius6
- 10.Gresham5
Local MSB operators by principal business address: registrants that list three or fewer states of operation. FinCEN MSB Registrant Search, Sep 29, 2026.
State regulator
Oregon Division of Financial RegulationThe Oregon Division of Financial Regulation licenses money transmitters in Oregon. Licensees also register with FinCEN, and the IRS examines MSBs for federal BSA compliance on FinCEN's behalf.
Sources and method
MSB figures come from FinCEN's MSB Registrant Search (Sep 29, 2026) and count principal business addresses; registrations at addresses shared by five or more MSBs are left out as registered-agent addresses. Mortgage lenders are 2025 HMDA filers; investment advisers are SEC-registered firms. GTO coverage comes from FinCEN's orders, and HIFCA status from FinCEN's HIFCA map.
A Faster Way to Build Your Oregon AML Program
No traditional consulting engagement. No proposals. No waiting. Our online platform gives Oregon businesses AML training, risk assessment reviews and policy documents, with training available the day you sign up.
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15+
Regulated Industries
Online
Delivery
113+
US Cities Covered
100%
FinCEN-Aligned
Also Operating In
Neighboring State Compliance Hubs
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