The Platform PM

Rules and risks

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.