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Crypto and stablecoin partner due diligence

A checklist for banks deciding whether to take on a crypto or payment-stablecoin fintech partner, and what to monitor after onboarding.

Licensing · BSA/AML · Travel Rule · GENIUS Act · Third-party risk

Interagency third-party risk guidance (OCC 2023-17, FDIC FIL-29-2023, FRB SR 23-4) expects banks to diligence, contract, monitor, and exit fintech partners with evidence. Crypto and stablecoin partners add MSB/MTL status, Travel Rule at $3,000, wallet screening, reserves and custody, and GENIUS Act readiness ahead of January 18, 2027.

Due diligence checklist

Licensing and MSB status

  • FinCEN MSB registration current, with change notices filed when required (31 CFR 1022.380).
  • State money transmitter licenses (or pending applications) in every state where customers are served.
  • NMLS call reports, renewals, net worth, and surety bond evidence current.
  • Clarity on whether the partner is (or will be) a permitted payment stablecoin issuer under the GENIUS Act.

BSA/AML and Travel Rule

  • Written AML program with CIP/CDD, independent testing, training, and a named BSA officer.
  • Travel Rule collection and transmission for transfers at or above $3,000, with exception handling.
  • SAR investigation and filing evidence for a recent sample period.
  • For payment stablecoin activity: gap analysis against the FinCEN/OFAC April 2026 NPRM (AML/CFT, CDD, SAR, U.S. AML officer, block/freeze, sanctions).

Sanctions and wallet screening

  • OFAC screening at onboarding and on an ongoing cadence, with documented hit disposition.
  • Wallet / blockchain analytics for sanctioned, mixer-linked, or high-risk addresses.
  • Policy for unhosted / self-hosted wallet transfers where applicable.
  • Periodic re-screening of the existing customer and wallet base.

Reserves, custody, and GENIUS Act status

  • Reserve composition, segregation, and custody arrangements (and how they map to 12 CFR part 15 if OCC-supervised).
  • Redemption procedures, SLAs, and recent performance evidence.
  • Attestations, audits, and capital/operational-backstop documentation.
  • Written plan to be ready by the GENIUS Act effective date of January 18, 2027.

Third-party risk and ongoing monitoring

  • Due diligence aligned to OCC 2023-17, FDIC FIL-29-2023, and FRB SR 23-4 across the relationship lifecycle.
  • Contractual rights to information, audit, remediation, and orderly exit.
  • Ongoing monitoring cadence by risk tier, with findings tracked to validated closure.
  • Board or committee reporting that shows the partner's exam-readiness evidence, not just policy attestations.

Download the printable due diligence checklist

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Proof points

Canarie is SOC 2 Type II certified. Review the Trust Center. Partner enablement includes Role Fintech for compliant card, payments, and stablecoin programs.

FAQ

What should a sponsor bank check before onboarding a crypto or stablecoin fintech?
Confirm MSB/MTL status, BSA/AML and Travel Rule operating evidence, sanctions and wallet screening, reserves and custody where relevant, GENIUS Act readiness for payment stablecoin activity, and third-party risk controls that match interagency guidance (OCC 2023-17, FDIC FIL-29-2023, FRB SR 23-4).
How does the GENIUS Act change sponsor-bank diligence?
For payment stablecoin partners, banks should ask whether the partner will be a permitted payment stablecoin issuer, how it meets (or plans to meet) OCC 12 CFR part 15 standards effective January 18, 2027, and how it is tracking FinCEN/OFAC's still-proposed AML/sanctions requirements. Diligence should demand evidence, not a slide deck.
Does every crypto partner need a money transmitter license?
Activity that transmits money or monetary value typically triggers FinCEN MSB registration and state MTL requirements. Structure, custody model, and state definitions matter. Require counsel-backed licensing opinions and current NMLS evidence rather than assuming a bank charter covers the fintech's own activity.
What ongoing monitoring should continue after onboarding?
Risk-tiered reporting, sample testing of Travel Rule and sanctions controls, reserve/redemption evidence where applicable, issue tracking to closure, and annual (or more frequent) partner reviews with refresh of licensing and GENIUS Act status.

Walk through a crypto partner evidence pack

See how sponsor-bank teams keep licensing, Travel Rule, and GENIUS Act items owned between exams.

Open GENIUS Act readiness