Size does not remove responsibility
A small company cannot excuse a weak compliance program by pointing to its budget. If a business offers a regulated service, it has to devote enough attention and resources to its obligations.
At the same time, a small payment company and a multinational bank do not have identical products, customers, systems, or risks. Their controls should reflect those differences. Copying the largest institution's structure is not the same as building an effective program.
The useful questions are specific. Who is responsible? What activity does the company handle? Which risks are present? How are concerns reviewed, and how does management know whether the controls are working?
Understanding why a control failed
No financial system prevents every instance of misuse. Customers can lie, steal identities, or conceal the purpose of a transaction. That does not make every failure unavoidable, and it does not make every failure evidence of criminal participation.
An investigation should examine what the company knew, what it was required to do, and how it responded. A warning ignored repeatedly may say something very different from a scheme concealed despite reasonable controls.
Accountability becomes more useful when those distinctions remain clear. It helps identify what must change and who was responsible for the decision, instead of treating the existence of a bad outcome as a complete explanation.
Large institutions are allowed to improve
Public enforcement records show large financial institutions paying substantial penalties and agreeing to reforms. Western Union's 2017 resolution involved a $586 million forfeiture. JPMorgan's 2014 Madoff-related resolution included $1.7 billion, and its 2020 market-manipulation resolution exceeded $920 million. Wells Fargo's 2020 sales-practices resolution totaled $3 billion.
Those are different cases with different facts and legal outcomes. They do not establish that another company deserves the same result. The penalties were substantial, and I do not describe them as inconsequential.
They do show that accountability can include an examination of controls, remediation, and continued operation. I believe a smaller company should receive a comparably serious assessment of its own facts, rather than have its size treated as a reason to doubt its good faith from the start.
Looking at the work a compliance officer actually does
My wife and cofounder, Sabreen Rihan, was designated as Crypto Dispensers' compliance officer from the beginning. She did not arrive with a traditional banking compliance résumé. That made learning, outside advice, and the actual performance of the role especially important.
We engaged AML consultants, financial technology lawyers, and other advisers. The work included licensing, monitoring, and independent reviews. Hiring those professionals did not transfer our responsibility to them. We still had to understand the advice, put appropriate controls into practice, and respond to weaknesses.
I want that work evaluated honestly. A title or résumé cannot prove that a program works. A nontraditional background cannot prove that it does not. The relevant record includes authority, training, resources, decisions, and follow-through.
An accusation can threaten the company before trial
I founded Crypto Dispensers in 2017. In November 2025, the government announced a money-laundering conspiracy charge against me and the company. We pleaded not guilty. The allegations must be decided through the judicial process; an indictment is not a finding of guilt.
For a smaller business, the practical effects of an accusation can arrive quickly. A bank may reconsider the relationship. A vendor may step away. Legal defense competes for the same resources that support employees and operations.
Those consequences do not excuse proven wrongdoing. They are a reason to make charging and enforcement decisions carefully, with an accurate understanding of the conduct and of what the available evidence establishes.
Taking responsibility for the company I built
My father came to this country believing a person could work, own something, and give a family a better future. I grew up with that belief, and it remains part of why I build.
It does not entitle me to special treatment. It gives me a reason to take the responsibilities seriously and to ask that the standards be applied fairly.
A company should fund compliance as necessary work. It should strengthen its program as its risks grow. And when its decisions are examined, the assessment should be based on what happened, rather than whether its founders came from the right institution or could afford the largest team.
