Make the next The BaaS Sponsor-Bank BSA/AML Lookback & Consent-Order Remediation release defensible before the deadline.

federal banking regulators have opened a recurring, well-documented wave of enforcement actions against small and mid-size "sponsor banks" — community and regional banks that rent their charters to fintech companies under Banking-as-a-Service (BaaS) arrangements — citing BSA/AML program failures tied specifically to inadequate oversight of those fintech partners.

lookbackclearbaassponsorbankbsaaml

Who this is for

A precise operating owner, not a generic audience.

Responsible buyer

Target Buyer Primary buyer: the BSA Officer or Chief Compliance Officer of a small-to-mid-size FDIC/OCC/Federal-Reserve-regulated sponsor bank (roughly $200M–$10B in assets) running one or more Banking-as-a-Service fintech-partner programs, who has just received a consent order, Matter Requiring Attention (MRA), or Matter Requiring Immediate Attention (MRIA) citing BSA/AML/KYC/SAR program deficiencies and mandating (or strongly inviting) an independent lookback review.

Cost of the gap

The bank facing this order is, almost definitionally, the same bank whose BSA/AML team was already too thin to catch the problem before a regulator did — it does not have spare internal capacity to staff a multi-thousand-account historical review on top of its ongoing compliance workload.

Outcome

The Outcome We Sell Not a transaction-monitoring dashboard the bank's own analysts must operate.

Decision rule

Proceed only when the source record, service boundary, responsible reviewer, and release criteria can be named before work begins.

Method

The work moves through visible states.

ScopeService Delivery Workflow Engagement scoping against the consent order's own language → secure data intake (transaction/account exports, CIP/KYC files) → AI normalization and typology screening across the full lookback population → AI-drafted per-account disposition and evidence package → analyst review and confirmation → BSA Officer review, correction, and attestation of every SAR-recommended account → SAR filing by the bank itself → delivery of the rolled-up lookback summary report → post-engagement retainer conversation.
CollectCollect only the source records required for the agreed work.
NormalizeNormalize records and preserve file-level provenance.
ValidateRun deterministic completeness and consistency checks.
ResolveRoute missing, conflicting, or unsupported items to an exception queue.
ReviewHave a qualified human review the release candidate.
ReleaseRelease the final pack with an audit trail and correction path.

Engagement

Buy the reviewed outcome, with boundaries written down.

Pricing Evidence and Proposed Pricing Tier Price Includes Engagement Setup & Scoping (one-time, per lookback) $15,000–$40,000 Consent-order scope mapping, fintech-partner data-schema ingestion, engagement plan aligned to the regulatory deadline, exception-queue design Per-Account Triage & Disposition (Tier 1 — clean file) $45–$65/account Automated typology screening, disposition (clear/escalate/SAR-recommended), evidence package, analyst review Per-Account Triage & Disposition (Tier 2 — escalation-required) $85–$110/account Tier 1 scope plus a written escalation memo and expanded evidence assembly for accounts requiring closer review Per-Account Triage & Disposition (Tier 3 — SAR-recommended

Release package

The Outcome We Sell Not a transaction-monitoring dashboard the bank's own analysts must operate.
The deliverable is the finished, examiner-ready artifact set: a complete per-account disposition log (clear / escalate / SAR-recommended) across the defined lookback scope; a fully documented evidence package per account (transaction summaries, supporting KYC/CDD records, and a cited audit trail of the reasoning behind each disposition); grounded, source-cited draft SAR narratives for every SAR-recommended account, queued for the bank's own BSA Officer to review, correct, attest, and file; and a rolled-up lookback summary report the bank can present to its own board and, through its own channel, to its examiner
all delivered against the bank's specific consent-order deadline, at a price known before the engagement starts.
A human-released operating pack with version history and a correction channel.

Proof standard

Operating evidence: No verified cycle-time result is published yet. The first result will be calculated from accepted intake through qualified-human release.

Client evidence: No client identity or case narrative is published. A reference may appear only after written permission and factual review.

Volume evidence: No completed-client count is claimed. Counts will be published only after the delivery ledger and provider records reconcile.

Evidence room

Authority comes from traceable sources, not decorative claims.

Open the full canonical blueprint dossier

Banking Dive — Piermont, Sutton banks hit with FDIC consent orders over BaaSSource identified in the canonical blueprint; verify currency before client reliance.
Banking Dive — A running list of BaaS banks hit with consent orders in 2024Source identified in the canonical blueprint; verify currency before client reliance.
Banking Dive — Fed hits Synapse partner Evolve with enforcement actionSource identified in the canonical blueprint; verify currency before client reliance.
Banking Dive — OCC cites AML deficiencies at NY bank that partners with fintechsSource identified in the canonical blueprint; verify currency before client reliance.
American Banker — Sponsor bank for Wise, Crypto.com told to fix AML programSource identified in the canonical blueprint; verify currency before client reliance.
OCC — Enforcement Actions for May 2026Source identified in the canonical blueprint; verify currency before client reliance.
Banking Dive — FDIC hits Alabama, Oklahoma banks with consent ordersSource identified in the canonical blueprint; verify currency before client reliance.
Financial Services Perspectives — The OCC's Recent Consent Order Is a WarningSource identified in the canonical blueprint; verify currency before client reliance.

Service boundary

Automation prepares. A qualified human releases.

LookbackClear is an operational documentation and processing service operated by Your Deputy, Obuke LLC. It is not a law firm and does not provide legal, tax, medical, financial, or other licensed professional advice. Consumer and personal debt matters are not accepted. The client retains its licensed professionals and decision authority. Automation may organize and check records, but a qualified human must review and release every client deliverable.

Unsupported facts remain unresolved, never inferred into a client deliverable.
Jurisdiction-specific or licensed questions are routed to the client's professional.
Every correction retains the source, reviewer, version, and reason for change.

Questions

Know the limits before intake.

Is this legal or professional advice?

No. This is bounded operational documentation and processing support. Licensed judgment remains with the client and its professionals.

Does automation make the final decision?

No. It can organize records, run declared checks, and prepare an exception queue. A qualified human reviews and releases every deliverable.

Is a client portal or CRM already active?

This public site does not claim an active portal integration. Portal access is provisioned only after the relevant backend is configured and independently verified.

What happens when evidence conflicts?

The item is placed in an exception state with its sources and owner. It is not silently resolved or presented as verified.

Fit diagnostic

Send enough context to scope the next conversation—no sensitive files.

Do not submit protected health information, personal financial data, credentials, or confidential client records through this public page.