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Eight Nine Risk & Compliance LLC
EIGHT NINE
— RISK & COMPLIANCE LLC —
Independent BSA/AML & OFAC Expertise

Your compliance program
has gaps.
Every single one does.
Find them first.

Eight Nine brings former Chief Compliance Officer and BSA Officer expertise to early-stage fintechs and sponsor bank programs — delivering independent audits and regulator-ready assessments at a cost structure built for where you actually are.

CCO
Former Chief Compliance Officers
BSA
Former BSA Officers
CAMS
Certified AML Specialists
15+
Years Executive Experience
The Problem
"Most fintechs don't get expert compliance help until it's already a crisis."

The compliance gaps that cost fintechs their sponsor bank relationships don't appear overnight. They're built in — through inconsistent onboarding, weak documentation, unclear escalation paths, and governance that exists on paper but not in practice.

  • Sponsor banks are tightening oversight of fintech programs significantly
  • Examiners assess whether controls actually work — not just whether policies exist
  • Documentation gaps turn manageable issues into formal regulatory findings
  • Enterprise compliance firms charge enterprise rates most fintechs cannot justify
What We Do

Three services.
One firm that
actually knows the work.

Not consultants who studied compliance. People who did it — at the CCO and BSA Officer level, at fintechs and banks, through examinations and remediations and enforcement conversations.

01
Independent BSA/AML Audits

Full-scope independent testing that produces regulator-ready findings — not a rubber stamp. The kind of audit that actually prepares you for what comes next.

  • CIP, CDD/EDD, OFAC, transaction monitoring
  • Regulator-ready findings and reporting
  • Examination support and examiner coordination
  • Control gap identification and prioritization
02
BaaS Due Diligence & Readiness

We know what sponsor banks look for — because we've been on both sides of the relationship. We prepare your program to pass the review the first time.

  • Sponsor bank KYB preparation and gap assessment
  • Controls and documentation alignment
  • Fintech–bank audit readiness reviews
  • Ongoing compliance partnership support
03
Program Design & Remediation

Build it right from the start, or fix what's broken before the examiners find it. Scalable frameworks designed for fintechs that are growing fast.

  • BSA/AML program builds from the ground up
  • Targeted control enhancements and gap remediation
  • Scalable frameworks that grow with your business
  • Policy and procedure development
Who We Serve

Built for companies
that need it most.

Whether you're a pre-revenue fintech seeking your first sponsor bank relationship, a growth-stage company preparing for examination, or a bank tightening oversight of your fintech portfolio — Eight Nine delivers the independent expertise to move forward with confidence.

Early-Stage Fintechs Growth-Stage Fintechs Sponsor Banks Community Banks BaaS Partners Payments & MSBs Lending Platforms Embedded Finance
Preparing for a sponsor bank
We prepare your program to pass the due diligence review — the first time. Gap assessments, documentation alignment, and control validation before the bank comes looking.
Fixing gaps before due diligence
Know where you stand before your sponsor bank or regulator tells you. Independent testing that identifies what needs to change — and how to fix it.
Preparing for regulatory exams
Examination readiness built by people who have managed examinations from the inside. Documentation, controls, governance — all aligned before the exam window opens.
Remediating compliance findings
A finding isn't the end. It's a test of whether your remediation program is credible. We build defensible plans that close issues and rebuild examiner confidence.
The Team

Not consultants who studied compliance.
People who did it.

Jacob Andolina
Jacob Andolina
Co-Founder & Managing Partner
CAMS BSA Officer CCO

Former BSA Officer and Chief Compliance Officer. Architect of BSA/AML/OFAC compliance programs at fintech startups. Jacob has sat in the exam room, written the policies, managed the examiners, and filed the SARs. Eight Nine exists because most fintechs don't get expert compliance help until it's already a crisis.

Patrick Doty
Patrick Doty
Co-Founder & Managing Partner
CAMS CRCM 15+ Years

Senior compliance executive with 15+ years leading enterprise compliance governance, regulatory transformation, BSA/AML strategy, and compliance modernization. Patrick has built enterprise Compliance Management Systems from inception through regulatory approval and advises financial institutions on designing scalable, regulator-ready programs.

Why Eight Nine

Executive pedigree.
Boutique agility.
The right price.

The large compliance firms bring large compliance firm overhead. You pay for brand, hierarchy, and junior associates learning on your dime. Eight Nine is different by design — and that difference shows up in the work and the bill.

01
Former CCOs & BSA Officers — not analysts

Every engagement is led by someone who has personally managed examinations, built compliance programs from scratch, and made the calls that matter. No junior associates. No learning curves on your budget.

02
Deep BaaS and fintech-bank fluency

We understand both sides of the sponsor relationship — what banks need to see and how fintechs actually operate. That dual perspective is rare, and it shows in the quality of the work.

03
Right-sized for your stage

Enterprise-quality audit work at a cost structure built for high-growth companies. No Big Four overhead. No generalist markup. Rates that reflect where you are, not where the big firms want you to be.

04
Independent. Objective. Credible.

Our independence is the point. We don't sell software, manage ongoing compliance, or have a stake in what we find. That objectivity is what makes our findings credible to examiners and sponsor banks.

Get In Touch

Ready to find the gaps
before they find you?

Schedule a free 20-minute conversation. No pitch, no obligation — just an honest assessment of where your program stands and what it would take to get it where it needs to be.

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