BSA/AML Compliance Leadership

Richard M. Mulder, CAMS

BSA/AML Compliance Leader — FinTech Oversight | AML Governance | Program Buildout

13+ years in financial services leading BSA/AML programs, sponsor-bank FinTech oversight, and AML governance at national institutions. Author of Strategies for BSA Officers.

Profile

About


Richard M. Mulder is a Certified Anti-Money Laundering Specialist (CAMS) with more than 13 years in financial services. He leads FinTech BSA/AML oversight at a sponsor bank, working with FinTech partners to build programs that meet bank and regulatory expectations — risk assessments, monitoring oversight, escalation discipline, and exam readiness. He also served a year in interim AML/CFT operations leadership, running day-to-day financial-crimes operations alongside his oversight role.

Before that, he spent seven years in BSA/AML governance and oversight at American Express National Bank; earlier still, he served as Chief Compliance Officer at Credit Corp Solutions, where he built and ran a consumer-compliance (FDCPA) program for a debt-collection firm. His work sits at the intersection of regulation, operations, and technology: translating BSA/AML requirements into programs that actually run.

Capabilities

Expertise


FinTech & BaaS Sponsor Oversight

BSA/AML Program Governance

BSA Risk Assessment

Transaction Monitoring Oversight

Sanctions & OFAC Compliance

Exam Readiness & Independent Testing

Policy & Procedure Governance

Team Leadership & Training

Career

Experience


Mar 2025 – Present

First Internet Bank

FinTech BSA/AML Oversight

Interim AML/CFT Operations leadership — Mar 2025 – Feb 2026

Jan 2018 – Feb 2025

American Express National Bank

BSA/AML Governance & Oversight

Jul 2014 – Jan 2018

Credit Corp Solutions

Chief Compliance Officer

Academic

Education


Brigham Young University B.S., Business Administration (2026)

Portfolio

Selected Work


Proof, not promises: a few things I've built.

AI-Assisted Oversight Reviews

I study how structured AI assistance can make compliance reviews more disciplined: breaking a review into careful, control-by-control questions so a human reviewer can test whether a program's design matches its documentation. My interest is the governance of it — AI as a rigorous checklist, never the decision-maker, and always inside approved tools and data boundaries.

Demonstrates:BSA/AML subject-matter depth + applied AI fluency.

The FinTech BSA/AML Guide (manuscript)

A complete 43-chapter draft of a practical guide to sponsor-bank BSA/AML — organised on a five-part framework: Classify → Assess → Build → Monitor → Escalate. Written for the partners and bankers who have to make FinTech compliance work in practice, not just on paper. Currently in development toward publication.

Demonstrates:program architecture + technical writing.

A Year Running Operations

Alongside my oversight role, I spent a year in interim AML/CFT operations leadership — running day-to-day financial-crimes operations while keeping the oversight program on track. Holding both seats at once gives me something most oversight professionals don't have: I know exactly what my expectations feel like from the operator's chair.

Demonstrates:operations leadership + oversight credibility.

ACAMS Chapter Leadership

Board Member & Co-Director of Communications, ACAMS Greater Salt Lake Chapter (2024–2026) — chapter programming, member communications, and events for the region's anti-financial-crime community, including a year serving remotely after relocating.

Demonstrates:industry leadership + professional community.

Free BSA/AML template downloads

The workbooks and framework behind the work above — free to download.

Complete BSA Template Workbook (Excel) BSA/AML Oversight Review Workbook (Excel) CDD/EDD Review Template (Excel) How I Build a BSA Program — Framework (PDF)

Excel workbooks download as ZIP archives — unzip to use them.

Track Record

Built, Not Inherited


An AML track record of programs built, not just maintained.

American Express National Bank, 2018–2025

Governance at Scale

Seven years in BSA/AML governance and oversight at a national bank: the frameworks, standards, and challenge routines that keep a large AML program coherent — and the discipline of defending that program to auditors and examiners.

First Internet Bank, 2025–present

The FinTech Oversight Build

Building sponsor-bank BSA/AML oversight of FinTech partners as a program, not a pile of reviews: partner risk assessment, monitoring expectations, escalation paths, and the evidence trail an examiner expects to find.

Interim AML/CFT operations leadership, 2025–2026

The Operator's Chair

A year running day-to-day financial-crimes operations alongside the oversight build. Most oversight programs are written by people who have never had to live inside one; this one was.

Publications & Community

Thought Leadership


3D book cover of Strategies for BSA Officers: A Practical Guide to Develop a Successful AML Program by Richard M. Mulder

Book

Strategies for BSA Officers: A Practical Guide to Develop a Successful AML Program

April 2025 · Also available as an Audible edition

Newsletter

AML Insights by Richard Mulder

A twice-weekly LinkedIn newsletter on BSA/AML practice for FinTech partners and compliance professionals.

In Development

BSA/AML for FinTech Sponsor Banking

A second book, on BSA/AML for FinTech sponsor banking, is in development.

Community

ACAMS Greater Salt Lake Chapter

2024–2026

Board Member & Co-Director of Communications.

Fiction

Also Writing as R.M. Mulder

Conquest: A Dystopian GameLit Saga — a dystopian GameLit series (Inception prequel; Ascension; Deception; Revelation; with Oppression, Damnation, and Salvation forthcoming).

Get in Touch

Contact


Interested in BSA/AML leadership, FinTech oversight, or speaking and writing on financial-crimes compliance? Connect on LinkedIn or by email.