Sector 02 / 09  ·  Payments · MSB

Payments and money services move value at speed. We build the controls that keep it clean.

Payment institutions, money remitters, exchange houses, e-money issuers and money services businesses sit on the fastest rails in regulated finance. That speed is the risk. Black Sea builds, remediates and runs the AML, sanctions and financial-intelligence programme behind a payments or MSB licence. The licence is the easy part. We build what sits behind it.

Get a costed plan → See coverage →
Sector Payments / MSB Coverage 19 markets Operator-side Theatre Frontier & Gulf
Scroll
OPERATIONAL
6
Distinct load factors
19
Markets served
5
Service lines
100%
Operator-side
02The operating reality
02

A payments or money services operator moves value between people who never meet. Each transaction is small, fast and final. At volume, the AML and sanctions load is heavy and it never pauses. The activity spans:

  • Remittance corridors and cross-border transfers
  • Currency exchange
  • Prepaid and e-money
  • Merchant acquiring and wallet top-ups

The exposure runs through every leg of the transfer: payer, payee, corridor, agent and settlement. The promise is instant, the obligation is thorough, and the programme has to resolve that tension without breaking either. Small, fast, final. That is the product and the problem in one line.

R/01
Velocity and volume
Thousands of transactions clear before a human sees any of them. Monitoring has to be automated, tuned and defensible, not a spreadsheet reviewed after the fact.
R/02
Cash and corridor risk
Cash-in, cash-out, high-risk corridors, agent networks and third-party payers create layering opportunities a bank-grade programme is not shaped for.
R/03
Sanctions on every leg
Every payer, payee, beneficiary bank and intermediary screened in real time, with logic for fuzzy matches and the discipline to clear false positives fast.
R/04
Travel Rule
Originator and beneficiary information travels with the payment. Where the framework requires it, collected, transmitted, retained, and gaps caught before settlement.
R/05
Agent and distribution networks
An MSB is only as clean as its weakest agent. Onboarding, monitoring and offboarding the network is part of the programme, not an afterthought.
R/06
Settlement speed vs review
The commercial promise is instant. The compliance obligation is thorough. The programme resolves that tension without breaking either.
03The examination

What a supervisor opens the file to find

When a central bank or financial-intelligence supervisor examines a payments or MSB operator, the questions are consistent across markets. They are about evidence, not intent. An examiner does not grade the policy, they grade whether the operator does what the policy says.

Test
Transaction monitoring that fits the model: rules calibrated to remittance, exchange and e-money typologies, alerts investigated and documented, backlog under control.
Test
Real-time sanctions screening: every party screened before value moves, list coverage current, and a screening decision from six months ago reproducible.
Test
Travel Rule compliance: where the framework requires it, originator and beneficiary data captured, transmitted and stored, and non-compliant counterparties handled.
Test
Customer and agent due diligence: CDD risk-rated and refreshed, the agent network onboarded, monitored and offboarded against clear standards.
Test
A named, empowered MLRO with authority, resources and a direct line to the board, and a complete, timely suspicious-transaction reporting record.
Test
Governance and the paper trail: board oversight, a current business-wide risk assessment, training records, independent testing, findings closed.
04The work

Five service lines, weighted equally. For a payments or MSB operator they connect end to end, from a new licence to a live, examinable programme we can run for you.

S/01
Licensing and new-regime programme build
We build what the application certifies.
The controls a payments or MSB application has to evidence: the business-wide risk assessment, AML and sanctions policies, the monitoring and screening design, the CDD and agent framework, and the governance to hold it together. Built to the standard of the supervisor named for your market, so the file stands up on first read.
S/02
Remediation, post-enforcement or post-finding
A fixed scope with a defined end.
When an examination or an enforcement action has exposed gaps, we run the remediation: alert and case backlogs cleared, monitoring rules retuned, screening logic rebuilt, look-backs scoped and delivered, and the record put back in a state a supervisor will accept.
S/03
Outsourced and bridge MLRO, with a managed FIU function
We run it, you own it.
A senior MLRO on your programme, permanent or as a bridge, plus the financial-intelligence engine underneath: alert triage, investigation, suspicious-transaction reporting and the analytics that keep monitoring honest.
S/04
Independent AML audit
The reviewer, not the seller.
The independent test a supervisor expects and a board should want. We examine the programme against the framework and the real transaction data, not the marketing, and hand you findings with a path to close them. We sell no software and take no commissions.
S/05
Sanctions, export-control and integrity DD, including the Travel Rule
Screening that holds on every leg.
Real-time screening design, watchlist governance, false-positive discipline, and the Travel Rule build where the framework requires originator and beneficiary data to travel with the payment. Integrity due diligence on counterparties, correspondents and agents where the corridor demands it.
See what we do in full →
05Coverage

One sector, every theatre

Payments and MSB is supervised in every market we cover, and the programme has to answer to the body that holds the register there. We build to the named supervisor, not to a generic template. A few anchors from across the coverage map:

UAE
The Central Bank of the UAE (CBUAE) licenses and registers exchange and payment businesses on the mainland, while ADGM's Financial Services Regulatory Authority and DIFC's Dubai Financial Services Authority supervise firms in the financial free zones.
Saudi Arabia
The Saudi Central Bank (SAMA) licenses and lists payment service providers.
Turkey
The Central Bank of the Republic of Türkiye (CBRT) authorises payment institutions, the Ministry of Treasury and Finance oversees authorised exchange offices, and MASAK, the Financial Crimes Investigation Board, holds the AML mandate.
Nigeria
The Central Bank of Nigeria (CBN) licenses and supervises payment service providers.
Kenya
The Central Bank of Kenya (CBK) maintains the directory of licensed money remittance providers.
South Africa
The South African Reserve Bank supervises the national payment system through its National Payment System Department, with the Financial Surveillance Department and the Financial Intelligence Centre carrying the exchange-control and AML mandates.
Kazakhstan
The National Bank of Kazakhstan registers payment organisations, alongside the Agency for Regulation and Development of the Financial Market.

The full matrix, market by market. Each page names the body that examines the programme:

AzerbaijanCBAR BahrainCBB EgyptCBE GeorgiaNBG GhanaBoG JordanCBJ KazakhstanNBK / ARDFM KenyaCBK KuwaitCBK KyrgyzstanNBKR NigeriaCBN OmanCBO PakistanSBP QatarQCB Saudi ArabiaSAMA South AfricaSARB / FIC TurkeyCBRT / MASAK UAECBUAE / FSRA / DFSA UzbekistanCBU
Even coverage. 19 markets. One programme, calibrated per supervisor.
06The honest line

We say no where the answer is no

Payments and money services are permitted across our coverage, but tightly gated, and the shape of what is allowed differs by market. Registration and licensing are conditions precedent, not formalities. Where a model cannot be run cleanly under the local framework, we tell you before you spend on it. We do not paper over a structure a supervisor will reject.

Enforcement target
Unlicensed value transfer is an enforcement target in every one of these markets.
Condition precedent
Exchange and remittance businesses operate only against a live authorisation from the named supervisor.
Perimeter differs
Corridors, settlement currencies and agent models are constrained differently by market; some activities are reserved to banks.
We verify first
The licensing position is checked against the named supervisor before we scope.
07Market x sector

The programme is built to the market. Start with a few, or open the full coverage map. A handful of the payments and MSB combinations:

Payments & MSB inUAE Payments & MSB inSaudi Arabia Payments & MSB inTurkey Payments & MSB inNigeria Payments & MSB inKenya Payments & MSB inSouth Africa Payments & MSB inKazakhstan Full matrixCoverage hub
See all markets and sectors →
08Proof
PartnershipLocal partnersLicensed local law-firm and compliance partners in our markets.Partners →
Published workBriefing seriesA standing series on frontier and Gulf financial-crime regulation, including payments and money-services supervision.Insights →
CredentialsCAMS / ICACredentialed practitioners, with front-line KYC and financial-intelligence experience on the team.The firm →
Fresh proofVerifiable todayCurrent dated evidence rather than client references. No published client names, no invented case studies.The record →

Tell us the model. We will tell you what it takes to run it clean.

NDA-first scoping. Fixed-scope plan within 48 hours. No hourly billing.
Book a scoping call → Get a costed plan →