Compliance Program Specialist · Soflo Consulting
Sofia Delgado is a Compliance Program Specialist at Soflo Consulting with expertise in mortgage lender AML requirements, Florida-specific regulatory obligations, and small business compliance program design. She works with non-bank mortgage lenders, title companies, and real estate professionals to build practical, examiner-ready compliance programs that fit the operational realities of smaller organizations. Sofia is a recognized expert on FinCEN's Geographic Targeting Orders and their impact on South Florida real estate transactions.
21 articles by Sofia Delgado
Customer Due Diligence - CDD - is one of the five mandatory elements of a BSA-compliant AML program, and it's the one most businesses get wrong. Not because it's complicated, but because the regulatory standard is higher than most businesses realize. Here's exactly what CDD requires and how to do it correctly.
April 12, 2026
Small businesses that fall under the Bank Secrecy Act often assume that AML compliance is for big banks with dedicated compliance departments. That assumption is one of the most expensive mistakes in financial compliance. Regulators apply the exact same five-element framework to a 10-person MSB that they apply to a regional bank.
March 1, 2026
Mortgage loan originators sit in one of the most unusual compliance positions in financial services - subject to BSA obligations but processing transactions that look nothing like a bank's. The regulatory framework was designed with banks in mind, but you're expected to apply it anyway. Here's what that actually means for your operation.
February 5, 2026
Florida's proximity to Latin America, its concentration of international capital, and its cash-intensive economy make it one of the most scrutinized states in the country from an AML perspective. Here's what operating a financial business in Florida means for your compliance obligations in 2026.
December 5, 2025
Suspicious Activity Reports are one of the most misunderstood compliance obligations in the BSA framework. Most businesses either over-file on irrelevant activity or under-file on genuine red flags. Here's the practical framework for getting it right.
November 22, 2024
FinCEN's Geographic Targeting Orders have expanded significantly since their introduction. The 2024 updates affect more markets, lower thresholds, and add new disclosure requirements. Here's what covered businesses need to know.
October 10, 2024
Independent testing is one of the five required elements of a BSA compliance program - and one of the most commonly skipped. Here's what it actually involves, who can perform it, and what happens when you don't have it.
August 28, 2024
Investment advisers have long operated in a regulatory gray zone on AML compliance. That's changing. Here's where the regulatory landscape stands in 2024 and what advisers need to do to prepare.
July 11, 2024
Banks are terminating MSB relationships at an accelerating rate. Here's what's driving de-risking, what banks actually want to see from MSB compliance programs, and how to protect your banking access.
May 30, 2024
An AML risk assessment is not a one-time exercise. Here are the seven events that require an immediate update - and why waiting for your annual review cycle can be a costly mistake.
April 11, 2024
Whether it's an internal review, an independent test, or a regulatory examination, an AML program review follows a predictable pattern. Here's what happens at each stage and how to prepare.
February 29, 2024
Check cashers face some of the most intense AML scrutiny of any MSB category. Here's the complete compliance framework for check cashing businesses and the specific areas where examiners focus.
January 17, 2024
Luxury retailers and art dealers have historically operated outside the BSA framework. That's changing. Here's what the emerging regulatory requirements mean for high-end retail and the art market.
November 14, 2023
Annual AML training is required, but what must it actually cover? Here's the core content that every BSA training program must include - and the role-specific additions that separate adequate programs from excellent ones.
October 9, 2023
Examiners don't just evaluate your AML program - they evaluate your documentation of it. Here's the specific documentation that examiners request in every BSA examination and how to organize it for maximum impact.
August 22, 2023
Human trafficking is one of FinCEN's national AML/CFT priorities. Here's what the financial red flags of human trafficking look like and how your compliance program should be designed to detect them.
July 3, 2023
The digital asset sector - including NFTs, DeFi protocols, and virtual currency exchanges - faces an increasingly complex AML regulatory environment. Here's where things stand in 2023.
May 17, 2023
Cannabis businesses operate legally under state law but remain federally illegal. Financial institutions that serve cannabis businesses face unique AML compliance challenges. Here's the current state of the law and the practical compliance framework.
March 27, 2023
Florida MSBs face compliance obligations from both FinCEN and the state Office of Financial Regulation. Here's what the OFR requires and how it differs from the federal BSA framework.
January 25, 2023
FinCEN finalized the beneficial ownership reporting rule in September 2022. Here's what the rule requires, who must comply, and how to start preparing before the January 2024 effective date.
October 3, 2022
In 2022, FinCEN proposed extending formal AML requirements to real estate professionals involved in non-financed transactions. Here's what the proposed rule would require and how the industry should prepare.
February 17, 2022
Schedule a free consultation with Sofia Delgado or another Soflo compliance specialist.
