A policy suite, not a template dump

Examiner-ready BSA/AML policies for fintech and crypto startups.

Six foundational compliance documents — customized to your business model, jurisdictions, and risk profile — drafted by a former Chief Compliance Officer. Not a generic template. Not a law firm invoice.

NO. 001 — UPDATED FOR 2026 EXAMINATIONS
EXAMINER
READY
Anti-Money Laundering
Compliance Program
Rev. 04.2026
SEC. 4.2.1
PAGE 12 / 47
§ 4.2 — Customer Risk Rating
Risk-Based Approach
The Company applies a customer risk rating methodology aligned with FFIEC guidance and NYDFS Part 504 expectations.
§ 4.3 — Enhanced Due Diligence
Built on real programs that passed scrutiny at —
BlockFi
FanDuel
15+ yrs fintech & digital assets compliance

Your bank partner just asked for your policy suite. You have two weeks.

"We need to see your BSA/AML program, KYC procedures, transaction monitoring rules, and vendor management policy before we can onboard you."
— Every sponsor bank, every partnership call
  • I. The templates online are useless. Generic, bank-focused, written before crypto existed, or stitched together from unrelated sources. They don't reflect how your business actually works.
  • II. Law firms quote $25K–$75K for a full policy suite and take eight weeks. You need it before your next board meeting.
  • III. Your fractional CCO is stretched thin across four other startups and can't draft from scratch in time.
  • IV. Examiners and bank DD teams can smell a template. A boilerplate program without your actual risk profile gets flagged in the first read.

Six documents. Your entire foundational program.

Every document is customized against a structured intake covering your products, customer types, transaction flows, jurisdictions, and third-party vendors. Delivered in editable Word format with a revision log and reviewer-ready formatting.

I.
AML Risk Assessment

Product, geography, customer, and channel risk scored against a defensible methodology. The document examiners ask for first.

~ 18 PAGES
II.
BSA/AML Program

The master compliance program document. Governance, roles, escalation, SAR workflow, training, independent testing. The anchor of your entire suite.

~ 45 PAGES
III.
KYC / CIP Policy

Customer identification, beneficial ownership, sanctions and PEP screening, EDD triggers. Tailored for retail, institutional, or mixed models.

~ 22 PAGES
IV.
Transaction Monitoring Procedures

Typology-based rules, thresholds, alert disposition, and escalation. Built to map against the monitoring stack you actually use.

~ 16 PAGES
V.
Vendor Management Policy

Third-party due diligence, tiering, ongoing monitoring, termination. What bank partners and examiners check after the BSA program.

~ 14 PAGES
VI.
Fraud Prevention Plan + Recordkeeping

Account takeover, first-party fraud, synthetic identity, and a recordkeeping policy that maps to §1010.410 and state retention rules.

~ 20 PAGES

Three tiers. Pick the one that matches what's on the line.

The right tier depends on whether you're preparing for an internal milestone, a bank partner onboarding, or a regulator-facing deadline. There's no upsell pressure — the Template tier is a real product, not a trap.

Template Pack
Self-service. For early-stage founders and in-house teams who can do the customization work themselves.
$899 one-time
INSTANT DOWNLOAD
  • All 6 foundational documents
  • Editable Word format with fillable fields
  • Completion checklist & guidance notes
  • Crypto-native and fintech-native variants
  • 12 months of template updates
Buy Template Pack →
Reviewed Suite
For companies facing bank DD, a state MTL application, or an examiner visit. Senior practitioner review on record.
$11,500 one-time
10-DAY TURNAROUND
  • Everything in Guided Suite
  • Line-by-line redline by former CCO
  • 90-minute review & walkthrough call
  • Cover memo describing scope & methodology
  • Two revision rounds included
  • 60 days of follow-up Q&A
Book scoping call →

From intake to examiner-ready, without an eight-week law firm engagement.

01
DAY ZERO
Intake

40 structured questions covering products, customers, jurisdictions, transaction flows, and your existing compliance stack.

02
DAYS 1–3
Drafting

Policies drafted against your intake, not pulled from a template library. Every document reflects your actual business.

03
DAYS 4–5
Review

Final quality pass and assembly. Delivery as a versioned, editable Word package with revision log and change summary.

04
ONGOING
Maintenance

Optional quarterly updates as FinCEN, OFAC, and state regulations change. Your program stays current without you tracking it.

Built & maintained by
David Spack
Principal, D Spack Consulting

Former Chief Compliance Officer at BlockFi and VP of Compliance & Enterprise Risk at FanDuel. Principal of D Spack Consulting, advising fintech and digital asset startups on BSA/AML, state licensing, and regulatory strategy. The policy architecture in Complyable is descended from live programs that passed bank partner due diligence, state regulator exams, and institutional counterparty scrutiny.

  • Chief Compliance OfficerBlockFi
  • VP, Compliance & ERMFanDuel
  • PrincipalD Spack Consulting

The templates online weren't written by a CCO who sat through examinations.

Compliance documents are only useful when they reflect how your business actually operates — and when the person who drafted them knows what examiners, bank partners, and state regulators look for first. Generic templates fail on both counts.

Complyable is built on the same policy architecture I've used to build live programs at BlockFi and FanDuel, and to advise startups through state MTL applications and bank sponsor due diligence. It's the kit I wish existed when I was a first compliance hire at an early-stage fintech.

Things people ask before they buy.

Is this a substitute for a compliance lawyer?

No, and it's not trying to be. Complyable gives you a defensible, examiner-ready policy foundation at a fraction of the cost of a law firm engagement. For sign-off on novel products, enforcement response, or litigation, you still need outside counsel. The Reviewed Suite includes a cover memo describing the scope of senior review, not a legal opinion or formal attestation.

Which business models are supported?

The core suite supports money transmitters, crypto exchanges and custodians, BaaS-stacked fintechs, neobanks, payments companies, and sports betting / iGaming operators. If your model sits outside those, the scoping call determines fit before you buy.

How customized is the Guided Suite, really?

Meaningfully. The 40-question intake drives product-specific, jurisdiction-aware drafting — KYC flows for a retail crypto exchange look very different from those for an institutional prime broker, and the output reflects that. You'll still want internal review before adoption, but the policies shouldn't read as generic.

What if a regulator changes something after I buy?

The Template Pack and Guided Suite include 12 months of template updates. A quarterly maintenance subscription is available separately for ongoing monitoring of FinCEN, OFAC, state MTL, and major bank partner expectations.

Can you sign an NDA before the intake?

Yes. Mutual NDAs are signed before any intake for the Guided Suite and Reviewed + Attested tiers. All engagements are handled under D Spack Consulting LLC.

Get your BSA/AML program off the starting blocks.

Three tiers, clear scope, practitioner-built. Pick the one that matches your deadline.