Find Out If Your Business Needs AML/BSA Compliance

Your business needs an AML/BSA compliance program if it is a "financial institution" under the Bank Secrecy Act. This includes money services businesses (MSBs), mortgage lenders and originators, banks and credit unions, fintech companies, casinos, insurance companies, and certain real estate professionals. Use our free self-assessment above to find out if your specific business is covered.

A Money Services Business (MSB) is any business that provides money transmission, currency exchange, check cashing, money orders, prepaid access, or virtual currency services. MSBs must register with FinCEN and maintain a written AML compliance program. Common examples include wire transfer services, check cashers, currency exchangers, and cryptocurrency businesses.

Mortgage lenders and originators are required to maintain a written AML/BSA compliance program under 31 CFR § 1029.210. This includes annual employee training, a designated BSA compliance officer, a written risk assessment, and an independent program review. Mortgage brokers who are not lenders are not currently covered, but this is subject to change.

Operating a covered business without an adequate AML program can result in civil money penalties from $71,545 to $286,184 per willful violation (31 CFR 1010.821, as adjusted January 2025), cease and desist orders, loss of operating licenses, and in serious cases, criminal prosecution. FinCEN has assessed penalties against businesses of all sizes for inadequate AML programs.

Traditional AML compliance consulting can cost $5,000–$50,000+ per year in hourly fees. Soflo offers a fixed-price annual compliance program that includes written policies, risk assessment, annual training with certificates, and independent review, starting at a fraction of traditional consulting costs. Use our self-assessment to get a personalized quote.

BSA (Bank Secrecy Act) is the U.S. law that requires financial institutions to maintain records and file reports to help detect and prevent money laundering. AML (Anti-Money Laundering) refers to the broader set of policies, procedures, and controls that businesses implement to comply with the BSA and related regulations. In practice, "AML compliance" and "BSA compliance" are used interchangeably.

Many business owners are caught off guard: auto dealers selling vehicles for more than $50,000 in cash, jewelry stores processing large transactions, real estate professionals handling all-cash deals, and even art galleries selling high-value pieces may all be covered by FinCEN regulations. Payment processors, digital wallet providers, and peer-to-peer lending platforms are also classified as financial institutions under the BSA. If your business moves money for customers in any capacity, you should verify your status.

Start with a compliance assessment. Determine whether your business activities fall under the BSA's definition of financial institution. Check if you are or should be registered with FinCEN as an MSB. Review state-level licensing requirements for money transmission or mortgage origination. Use our free self-assessment above, it takes 2 minutes and provides a personalized analysis of your AML obligations.

Yes, you can build and manage an AML program internally, but it requires significant expertise in FinCEN regulations and current examination standards. Most small to mid-sized businesses find that a compliance platform like Soflo delivers better results at a lower cost than hiring an in-house compliance officer or paying hourly consulting fees.

If your business is currently operating without the required AML program, every day is a risk. FinCEN can examine your business at any time, and state regulators conduct routine examinations. The good news: a comprehensive AML program can be implemented in 2–4 weeks with Soflo, and employee training is available immediately after subscribing.