Finstack LLC, doing business as SprintPay — the brand and operating name under which it provides payment services — is a Money Services Business registered with FinCEN (Registration #31000323879688). We maintain a comprehensive Anti-Money-Laundering and Counter-Financing of Terrorism (AML/CFT) program designed to comply with the Bank Secrecy Act (31 U.S.C. § 5311 et seq.) and its implementing regulations at 31 CFR Chapter X.
1. Designated Compliance Officer
Our Compliance Officer is responsible for day-to-day oversight of the AML/CFT program, reports to the Board of Managers, and is the primary point of contact with law enforcement and FinCEN.
2. Customer Identification & Due Diligence
We apply risk-based customer due diligence (CDD) for every customer, including identity verification (KYC), business verification (KYB), beneficial-ownership identification, sanctions and PEP screening, and adverse-media review. We apply Enhanced Due Diligence (EDD) for higher-risk customers and transactions.
3. Sanctions screening
All customers and counterparties are screened against the OFAC SDN list, OFAC consolidated sanctions lists, UN, EU and UK sanctions lists prior to onboarding and on an ongoing basis. We do not knowingly transact with sanctioned persons or in sanctioned jurisdictions.
4. Transaction monitoring
Transactions are monitored against rule-based and behavioral models. Alerts are triaged by trained analysts. Suspicious activity is investigated and, where appropriate, reported to FinCEN through Suspicious Activity Reports (SARs) within applicable deadlines.
5. Recordkeeping & reporting
We retain records required under the BSA (including customer identification, transaction logs and SAR documentation) for at least five years. We file Currency Transaction Reports (CTRs), SARs and any other reports required by FinCEN or other competent authorities.
6. Travel Rule
For transmittals subject to the Travel Rule (31 CFR 1010.410(f)), we collect and transmit originator and beneficiary information as required. For convertible virtual currency transmittals, we apply equivalent controls in line with FinCEN guidance.
7. Independent testing
Our AML program is independently tested at least annually by qualified internal or external reviewers, with results reported to senior management and the Board.
8. Training
Employees in client-facing, operational and compliance roles receive AML/CFT training upon hire and annually thereafter. Training is documented and tested.
9. Cooperation with authorities
SprintPay cooperates with lawful requests from FinCEN, state financial regulators and law enforcement.
10. Contact
For AML inquiries: compliance@sprintpay.io.