· FINTRAC
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.
Tag: AML
- · FINTRAC
Documentation matters more than policy language
In a FINTRAC examination, the records that show how the compliance program runs carry more weight than the policies that describe it.
- · Crypto
On-chain and off-chain AML visibility
The gap between what blockchain-based payment flows reveal and what FINTRAC compliance requires is a design problem, not an exemption.
- · FINTRAC
Six pillars of MSB defensibility
A defensible AML compliance program for Canadian MSBs is built on six elements that FINTRAC examines both as documentation and as operating evidence.
- · Crypto
Stablecoin treasury products and Canadian AML risk
Companies using stablecoins for treasury operations need to assess whether the activity engaged constitutes dealing in virtual currency under Canadian law.
- · FINTRAC
Suspicious transaction reporting: when legal triage is needed
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.