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Fractional Chief Risk Officer (CRO) Services

Senior Risk Leadership Without the Full-Time Cost

The Retail Payment Activities Act (RPAA) requires Payment Service Providers (PSPs) to designate a senior officer accountable for risk management, safeguarding, and incident response. For many PSPs, appointing a full-time Chief Risk Officer (CRO) is not feasible.

AML Incubator provides Fractional CRO services, allowing organizations to access senior-level risk expertise and governance oversight on a flexible basis. This service ensures that PSPs meet all RPAA requirements while reducing the cost and complexity of building an internal executive function.

What the Fractional CRO Provides

The Fractional CRO acts as the designated accountable officer under the RPAA. Responsibilities include:

Maintaining and updating governance and compliance policies.

Conducting quarterly compliance reviews and providing board-level reporting.

Supporting annual compliance attestation filings with the Bank of Canada.

Maintaining the Risk Management & Incident Response Framework (RMIRF).

Overseeing vendor and third-party risk management.

Advising on safeguarding of end-user funds, liquidity, and settlement practices.

Ensuring user disclosures, complaints handling, and incident notifications remain compliant and effective.

Deliverables

Clients engaging AML Incubator for Fractional CRO services receive:

An updated RPAA-compliant policy suite.

Quarterly compliance and risk review reports.

Board briefing packages.

Monthly reconciliation and safeguarding reports.

Updated disclosure templates and user communication materials.

Advisory support during material incidents.

An annual compliance attestation package for the Bank of Canada.

Quarterly training refreshers for staff.

Benefits of Fractional CRO Services

Regulatory compliance

Regulatory compliance

Meets the RPAA requirement for a senior officer accountable for risk.

Cost-effective oversight

Cost-effective oversight

Provides senior risk leadership without the burden of a full-time hire.

Regulator readiness

Regulator readiness

Maintains documentation, evidence, and reports for supervisory reviews.

Independent governance

Independent governance

Strengthens board oversight and management accountability.

Specialized expertise

Specialized expertise

Leverages AML Incubator’s global experience across fintech, MSBs, and payment providers.

Who Benefits from Fractional CRO Services

Payment Service Providers (PSPs) registered under the RPAA.

FinTech companies and startups seeking investor and banking partner confidence.

Money Services Businesses (MSBs) requiring integrated risk and compliance governance.

Crypto exchanges and VASPs operating under multiple jurisdictions.

Banks and neobanks seeking outsourced or interim CRO leadership.

AML Incubator Advantage

AML Incubator combines deep regulatory expertise with technology-driven oversight. By integrating risk management, safeguarding, and compliance into a single service, the firm ensures that clients remain regulator-ready at all times.

The Fractional CRO service allows PSPs to fulfill RPAA obligations, reduce regulatory risk, and build trust with regulators, investors, and counterparties.

Your Trusted Partner in Regulatory Excellence.

Frequently asked questions

What is a Fractional CRO and how is it different from CAMLO or MLRO?

A Fractional CRO owns enterprise risk, safeguarding, vendor oversight, and incident management under RPAA. CAMLO or MLRO focuses on AML and reporting obligations. Many PSPs use both roles, coordinated for complete compliance coverage.

Does the RPAA require a named senior officer for risk?

Yes. PSPs must appoint a senior officer accountable for risk management, safeguarding, and incident response. AML Incubator’s fractional model fulfills this requirement for supervision readiness.

What evidence will a supervisor expect during a review?

Adopted policies, risk registers, reconciliations, incident logs, third-party due diligence, training records, board reporting, and the annual attestation package.

How does AML Incubator support the Bank of Canada attestation?

The Fractional CRO prepares the attestation pack, aligns supporting evidence, briefs management and the board, and coordinates responses to supervisory queries.

How are incidents handled?

The Fractional CRO leads triage, assesses impact, coordinates notifications to the Bank of Canada and end-users when required, and documents root cause and corrective actions.

Can the service integrate with existing systems?

Yes. The service works with existing ticketing, governance, risk, and compliance (GRC) tools, monitoring platforms, and vendor systems—or AML Incubator recommends suitable partners where gaps exist.

any other QUESTIONS?

If you have questions, we have answers for you here. In case we don’t, please feel free to reach out to us here hello@amlincubator.com
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