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.
Embedded finance products distribute commercial and compliance responsibility across multiple parties — and the allocation only works if the agreements reflect what actually happens.
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 monitoring gaps most likely to produce FINTRAC findings are not technology failures — they are documentation and design failures.