Anti-Money Laundering (AML) Compliance Template

If your product qualifies as a Money Services Business (MSB) under FinCEN rules, yes. MSBs include money transmitters, payment processors, currency exchangers, and issuers of stored value. If you operate under a banking partner's license, the partner's AML obligations typically flow down to you via contract. Even if you are technically exempt, banking partners and payment networks (Visa, Mastercard) require AML controls as a condition of partnership.

KYC (Know Your Customer) is the broad category of customer identification and verification. Customer Due Diligence (CDD) is a specific component of KYC required by FinCEN's CDD Rule. CDD requires collecting and verifying beneficial ownership information for legal entity customers. Enhanced Due Diligence (EDD) is the elevated scrutiny applied to high-risk customers such as politically exposed persons (PEPs) or customers in high-risk jurisdictions.

Start with regulatory minimums (CTR threshold at $10,000, structuring detection for transactions just below $10,000). Then layer product-specific rules based on your customer risk profiles: unusual velocity spikes, geographic anomalies, transactions inconsistent with stated business purpose. Calibrate thresholds using historical data to balance detection rates against false positive volume. A false positive rate above 80% typically indicates over-broad rules.

Common EDD triggers include: PEP matches during onboarding, customers in FATF high-risk jurisdictions, businesses in high-risk industries (cash-intensive businesses, cryptocurrency, gambling), unusually large or complex transaction patterns, and adverse media screening hits. Document your EDD criteria in your AML policy and apply them consistently.

AML features are not optional. Treat them as foundational infrastructure, not feature requests. KYC onboarding flows directly affect conversion rates, so design them to minimize friction while meeting compliance requirements. Transaction monitoring affects processing latency, so work with engineering to optimize for both speed and accuracy. The [Technical PM Handbook](/technical-pm-guide) covers how to balance technical infrastructure work with product priorities. ---