FINTRAC/PCMLTFA compliance programs for MSBs, VASPs, and lenders. We draft the AML/KYC policy, run your MLRO function, stand up transaction monitoring, and prep you for FINTRAC exams.
Every FINTRAC reporting entity reviews its compliance program every two years: policies and procedures, the risk assessment and the training program, with documented tests and an action plan. We run it as an external reviewer: AML compliance audit in Canada. MSBs starting out read MSB registration in Canada first.
FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) is Canada's financial intelligence unit, established under the PCMLTFA. It receives, analyses, and passes financial intelligence to law enforcement. Every MSB, bank, securities dealer, real estate broker, and other reporting entity registers with FINTRAC and files reports — Large Cash Transaction Reports (CAD 10,000 or more) and Suspicious Transaction Reports.
Any reporting entity under the PCMLTFA must keep a written AML/ATF compliance program. The list runs: MSBs (foreign exchange, money transfers, virtual assets), banks and credit unions, insurers, securities dealers, real estate brokers, casinos, accountants, and precious-metals dealers. Non-compliance draws administrative penalties up to CAD 500,000 and criminal penalties up to CAD 2 million.
The PCMLTFA is Canada’s primary anti-money-laundering statute, administered by FINTRAC jointly with the Department of Finance. It requires reporting entities to: identify clients (CDD/EDD), keep prescribed records for at least five years, report suspicious transactions, large cash, and cross-border currency movements, and run a five-element compliance program. FINTRAC examinations typically come every 3–5 years.
A PCMLTFA program rests on five mandatory elements: (1) written policies and procedures; (2) a designated compliance officer (MLRO); (3) a written risk assessment of clients, products, and channels; (4) documented employee training; (5) an independent effectiveness review at least every two years. All five components, for MSB and fintech clients, we build and maintain.
The PCMLTFA requires an independent effectiveness review of the compliance program at least every two years — run by someone functionally independent of day-to-day compliance, usually a third-party consultant or internal audit. The review covers all five elements, records its findings, and sets a remediation plan. FINTRAC examiners take the most recent review report as the primary inspection document.
