Common AML program failures for Canadian MSBs
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental — and most are preventable.
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental — and most are preventable.
In a FINTRAC examination, the records that show how the compliance program runs carry more weight than the policies that describe it.
Canadian fintech regulation turns on what a product does, not what it is called — and the analysis starts with the flow of funds.
FINTRAC examinations test operating evidence, not just policy documents — preparation means assembling the records that show how the compliance program runs in practice.
A defensible AML compliance program for Canadian MSBs is built on six elements that FINTRAC examines both as documentation and as operating evidence.
The STR decision turns on reasonable grounds to suspect, not proof — and the line between a compliance decision and a legal one is not always obvious.