How a UK Firm Should Structure Its First 12 Months Entering the US Market

How AnyAccount Helps

At AnyAccount, our US team supports FinTech founders, MSBs and scaling payment companies with:

• State and federal regulatory licensing strategy, including MSB and money-transmitter frameworks

• Bank sponsorship readiness and partner-bank compliance alignment

• Technology market launches, including payments infrastructure and AML/KYC controls

• End-to-end MSB governance frameworks with operational playbooks and audit trails

• Examination preparation across FinCEN, state regulators and sponsor-bank reviews

If you want to enter the US market without spending your first year learning everything the hard way, speak to us. We help UK and EU firms build US-ready regulatory, operational and governance architecture from day one.

The US market remains the most commercially attractive — and operationally unforgiving — landscape for FinTechs. It offers scale that Europe cannot match and a consumer base that adopts digital financial products at extraordinary speed. But it is also fragmented, rules-light but enforcement-heavy, and governed as much by sponsor banks as by regulators.

For a UK firm accustomed to the FCA’s structured supervision, the first year in the US can feel like learning a new language while running a marathon. The trick is sequencing: doing the right things in the right order.

Here’s how a UK FinTech should structure its first 12 months if it wants to enter the US successfully.

Months 1–3: Strategy, Structure and Regulatory Positioning

The first quarter is about planning, architecture and decisions that will define the next five years.

A UK firm should begin by mapping its entry model — will it operate through a sponsor-bank programme, pursue state licences immediately, use an agent model, or blend approaches? These aren’t tactical questions; they determine product design, compliance requirements, vendor choices and capital needs.

Sponsor-bank fit is critical at this stage. Banks want to understand your risk profile, onboarding model, customer base, settlement flows and operational controls. Firms that treat the bank as a formality often hit brick walls before they even enter contract negotiations.

At the same time, leadership should engage US counsel and compliance specialists to map federal obligations (FinCEN, OFAC) and determine whether the firm falls into MSB or money-transmitter categories. These decisions inform how quickly the business can launch and how soon licensing must begin.

Months 4–6: Building US-Ready Governance and Operational Controls

The second quarter is when UK governance models start to bend under US expectations.

Sponsor banks and state regulators want operational specificity. Firms must begin building:

• a US AML programme with named accountable individuals

• policies aligned to US regulatory language (not repurposed FCA manuals)

• onboarding workflows reflecting US verification requirements

• transaction monitoring rules tailored to US typologies

• vendor governance models with real evidence trails

• data-handling arrangements meeting state privacy laws

This is also when vendor selection occurs — from KYC and fraud tools to payment processors and ledgering systems. The US ecosystem differs from Europe’s; choosing the wrong vendor at this stage creates costly re-platforming later.

Months 7–9: Sponsor Bank Approval, Compliance Build-Out and Initial Pilots

By mid-year, the operational model should be ready for sponsor-bank diligence. This includes audits, walkthroughs, tabletop scenarios and deep technical reviews.

Banks typically want to see:

• governance structures

• risk assessments

• BSA/AML staffing

• fraud rules and testing logs

• customer-facing UX

• escalation protocols

• business continuity and disaster recovery documentation

• vendor files with full due diligence

This period is also when engineering teams finalise API integrations with the bank’s core systems and card network processors (if applicable). Firms often underestimate how iterative this stage is; US sponsor banks expect continuous response cycles, not a single static submission.

If approved, firms may begin closed-loop pilots, internal testing and staged customer launches under the bank’s oversight.

Months 10–12: State Licensing, Market Launch and Exam Readiness

Once operating smoothly under a sponsor-bank programme, the final quarter focuses on expansion, licensing and tightening controls ahead of regulatory examinations.

Many firms begin the multi-state money-transmitter licensing process at this point, which involves:

• surety bonds

• financial audits

• business plans

• AML procedures

• governance documentation

• background checks

• net-worth requirements

It’s also when firms should initiate exam readiness — building exam binders, evidence packs, audit logs and operational proof that controls work in practice.

Meanwhile, marketing, growth and customer acquisition strategies begin rolling out in coordination with sponsor-bank marketing guidelines and consumer compliance oversight.

By the end of the first year, a UK firm should aim to be:

• live with a compliant, scalable US customer product

• embedded within a sponsor-bank governance framework

• progressing through state licensing

• ready for its first regulatory or bank examination

Firms that reach this point without material issues generally succeed in the US. Those that treat the year as an experiment rarely make it to year two.