◆ Quick answer
A fintech AUP template should include a three-tier classification (Prohibited / Restricted / Permitted), a sales intake questionnaire with auto-routing, a bank-partner alignment matrix, an exception memo template, monitoring triggers, and an RFI volume KRI tracker for sponsor bank early warning.
Guide vs. template
This guide explains what belongs in the template. The paid template gives you the editable working files so you're not rebuilding from a blank page.
Paid template includes
- ◆ 16-tab Excel workbook (213 formulas, 10 data validations, 15 conditional formatting groups)
- ◆ Sales Intake Questionnaire — 22 weighted questions, auto-routes to Approve / Conditional / Escalate / Decline
- ◆ Tier Master List — 40 categories across Prohibited / Restricted / Permitted, each with regulatory anchor and typical bank partner position
- ◆ Bank Partner Alignment Matrix — your AUP vs sponsor bank, gap-flagged with formulas
What is this template for?
A fintech Acceptable Use Policy (AUP) is the framework risk and compliance teams use to decide which customers and use cases can be onboarded — and how. The useful version separates customer category from use case (a cannabis retailer running payroll is different risk from one processing consumer cannabis sales), classifies every category into three tiers (Prohibited / Restricted / Permitted), maps each tier to your sponsor bank's program agreement, and runs a low-touch sales intake that auto-routes deals (Approve / Conditional / Escalate / Decline) without forcing Sales to make risk judgments.
◆ Audience
Who needs this.
- ◆ Your sponsor bank, an examiner, or your CCO asked how you evaluate high-risk customers like cannabis, MSBs, crypto, gambling, firearms, or payday.
- ◆ Sales and Compliance are arguing about every gray-area deal because there's no shared decision framework.
- ◆ You operate under a sponsor bank program agreement and need a documented bank-partner alignment artifact.
- ◆ You've received RFIs from your sponsor bank and want an early-warning KRI tracker so the next pattern is visible before it becomes formal.
- ◆ You need a defensible Exception Memo format that holds up to examiner review (FFIEC BSA/AML EDD documentation expectations).
◆ Implementation roadmap
How to roll this out.
Pull your sponsor bank's prohibited / restricted business schedule and map every category in your AUP against it
Owner · Compliance / Risk lead with bank liaison input
Output · Bank Partner Alignment matrix with Gap flags (Aligned / Gap / Material Gap) — Material Gaps must be addressed before any further onboarding in that category
Brief Sales on the Intake Questionnaire — they fill factual options only, the formula calculates the rating
Owner · CCO or BSA Officer with Sales lead
Output · Sales knows: pick the closest factual description, the spreadsheet rates, the auto-routing decides whether to escalate
For every Conditional / Escalate outcome, run Compliance EDD and complete the 10-section Exception Memo
Owner · Compliance analyst with BSA Officer / CCO sign-off
Output · Memo signed before onboarding; conditions and monitoring baselines documented; bank pre-clearance reference attached where required
Configure transaction monitoring per the memo's baselines — volume, counterparty scope, product scope, settlement patterns
Owner · Compliance + Fraud / Ops
Output · Triggers configured in the monitoring platform; behavioral signals route to Compliance review when fired
Track RFI volume from sponsor bank as an early-warning KRI; rising trend in any category escalates to TPRM governance
Owner · Compliance / Bank Liaison
Output · Monthly RFI count by category with cumulative YTD and Rising / Stable trend; persistent unresolved RFIs precede formal warnings (the 2024 BaaS consent order pattern)
◆ Ready to use it?
Download the Fintech Customer AUP Kit.
Use the guide to understand the structure, or buy the editable template to move faster.
◆ FAQ
Frequently asked questions.
What should be included in a fintech Acceptable Use Policy template? ⌄
At minimum: a three-tier classification (Prohibited / Restricted / Permitted), the sales intake questionnaire that auto-routes deals to one of four outcomes, a bank-partner alignment matrix mapping your AUP to your sponsor's program agreement, a 10-section Exception Memo template, a monitoring trigger library with default thresholds for behavioral signals, an RFI volume KRI tracker, and an Exit Trigger Log so off-boarding decisions are criteria-based rather than improvised.
How is a fintech AUP different from a KYC or AML policy? ⌄
The AUP decides whether the customer or activity is eligible to be onboarded at all (and under what conditions). KYC / Customer Due Diligence decides how closely you review the relationship once it's approved. Transaction monitoring decides what you flag in ongoing activity. The AUP is the upstream gate; KYC and monitoring sit downstream.
Do I have to send every deal through this questionnaire? ⌄
No. The Sales Intake Questionnaire is designed so 80–90% of standard deals return "Approve" and proceed via standard onboarding without compliance review. Sales only sends it to Compliance when the auto-routing returns Conditional Approval / Escalate / Decline. The structured factual questions ensure that when a deal does need a deeper look, Compliance doesn't re-ask the same questions — the intake pre-populates the EDD checklist.
How does this fit with my sponsor bank's requirements? ⌄
Your AUP cannot be more permissive than your sponsor bank's program agreement — the bank is the chartered entity, examiners examine the bank's oversight of you. The Bank Partner Alignment matrix is the artifact that proves the mapping was done. Material Gaps (your AUP more permissive than the bank's) must be addressed before any further onboarding in that category. Pre-clearance for Restricted categories must be in writing.