Faisal KhanAnswered Oct 19, 2026Yes, that can be the structure, subject to the principal’s approved program and your agreement. A delegate may retain its brand, customer-facing application, merchant integrations, commercial relationships, user experience, internal reporting, and pricing model within the agreed scope.
You integrate those capabilities with the principal’s regulated infrastructure. Depending on the program, payment processing, ACH, pooled or FBO banking, the regulatory ledger, KYC/KYB, screening, monitoring, and payout rails may need to be provided by, routed through, or expressly approved by the principal.
That means you should settle vendor choices before onboarding. Having an existing KYC provider, processor, or bank account does not establish that the principal will accept it. If you want to use your own identity-verification provider, confirm whether the principal permits that arrangement and obtain the necessary approval before relying on it.
Your commercial customer relationship can continue, including separate agreements for technology services. The regulated payment service also needs appropriate customer terms and disclosures. Those can be integrated into your app, but customers must understand the principal’s role and your delegate status.
Keeping your pricing model also requires agreement on how fees and FX margins are recorded and settled. Do not assume that you can deduct fees or group settlements however you wish before the provider confirms the mechanics.
One important qualification: sponsorship does not remove the delegate’s own applicable compliance obligations. FinCEN makes clear that principals and agents each retain responsibility for adequate AML programs, even when contracts allocate particular tasks. FinCEN guidance on principal and agent responsibilities.
I would make this division of responsibilities clear before committing: what you control commercially, what the principal must approve operationally, and how both parties meet their obligations.