Field Guide
B2B payments: cross-border payouts
07
Rules and risks
2 min read · Chapter 7 of 10
How the rules work
For cross-border payouts the gap between written and enforced is wide, and it mostly favors B2B.
State money transmission
- Written
- Licences in every state but Montana
- Enforced, 2024 to 2026
- Exams and fines: a $4.2M six-state AML order (2025); $155,000 in Florida, $75,000 in Texas (2026)
- Felt in B2B payouts
- High: gates launch
FinCEN BSA
- Written
- Registration, AML, SARs, travel rule
- Enforced, 2024 to 2026
- Few, large cases; a sweep of over 100 border money businesses (Dec 2025)
- Felt in B2B payouts
- Medium
OFAC
- Written
- Strict liability, 10-year look-back
- Enforced, 2024 to 2026
- 12 to 17 actions a year; failures on location data
- Felt in B2B payouts
- High
CFPB Remittance Rule
- Written
- Consumer senders only
- Enforced, 2024 to 2026
- A suit dropped; a penalty cut from $2.025M to $45,000 (2025)
- Felt in B2B payouts
- Low
Remittance excise tax
- Written
- Cash-funded transfers only
- Enforced, 2024 to 2026
- Live; penalty relief through Q3 2026
- Felt in B2B payouts
- About none
FINTRAC
- Written
- Registration, reports, travel rule
- Enforced, 2024 to 2026
- Record notices; caps ×40
- Felt in B2B payouts
- Rising
RPAA
- Written
- Registration, safeguarding
- Enforced, 2024 to 2026
- A compliance order (Feb 2026); notices published since June 2026
- Felt in B2B payouts
- Medium to high
FATF R.16
- Written
- A standard
- Enforced, 2024 to 2026
- National laws by 2030
- Felt in B2B payouts
- Design the data now
Partner policy
- Written
- Contract
- Enforced, 2024 to 2026
- Immediate
- Felt in B2B payouts
- Highest
- OFAC finds fintechs through geography. A wallet paid $3.10M in 2025 after staff told Iranian users to use VPNs.
- Canada raised the stakes. FINTRAC's largest penalty, about CAD 177M, hit a crypto and payments business in October 2025, and maximum penalties rose 40-fold on March 26, 2026. I found none against a B2B payout firm.
- Destinations keep moving. Beyond India's and Brazil's October 1, 2026 rules, the Philippines' Circular 1206 gives foreign remittance platforms two years to operate through a local subsidiary.
From what I found, B2B payout regulation mostly bites through licences and partners, and the public penalties cluster on crypto, cash-heavy money services and consumer remittance.
What mistakes cost
The expensive mistakes mostly show up after the payout:
- Trapped money. After FinCEN's orders, the Mexican bank among the three institutions went into liquidation on October 10, 2025, with deposit insurance up to 400,000 UDIs (about MXN 3.4m). A provider prefunding pesos there owns the loss.
- Bank access. One partner bank's worry can close a whole country overnight, as in 2024.
- Penalties. From five- and six-figure state fines for unlicensed transmission to FINTRAC's CAD 177M.
- Employment law. Brazilian claims seeking recognition of employment rose 57% in 2024, and a Supreme Court ruling on hiring workers as companies is pending. My Mexican estimate is $54,000 for two years.
- Identity. Fake remote workers mean frozen funds and sanctions exposure.
I found no public case of a B2B payout firm losing its correspondent and freezing payouts in 2025 or 2026, which may only mean it isn't reported.