Financial Crimes & AML Compliance in Canada: What You Must Understand to Build a Strong Program
“Financial crimes” is a broad term encompassing money laundering, terrorist financing, sanctions evasion, fraud, the movement of illicit proceeds and other offences that exploit the financial system. In Canada, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) enforces the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations which require certain businesses (termed “reporting entities”) to implement compliance programs, identify clients, keep records and report suspicious activity.
Key Financial Crimes & Why Businesses Are Targeted
Some of the central financial crimes businesses must guard against:
Money laundering: when criminals attempt to disguise the illicit origin of proceeds through multiple transactions or entities.
Terrorist financing: providing, collecting or using funds to support terrorist activity.
Sanctions evasion: transacting with persons, entities or jurisdictions subject to trade or financial sanctions.
Fraud-related proceeds: e.g., cybercrime, ransomware payments, high-risk jurisdictions.
These activities may take advantage of businesses that deal in cash, virtual currency, cross-border transfers, precious metals, or high-value goods. FINTRAC’s 2023-2026 AML/ATF Strategy emphasises that more than 24,000 businesses in Canada are “front-line” defenders in this regime.
Business Obligations for AML Compliance in Canada
If your business falls under the PCMLTFA reporting-entity definition, you must implement a compliance program that meets FINTRAC’s requirements. According to the guidance, core elements of a program include:
Appointment of a Compliance Officer.
Written policies and procedures, kept up-to-date, approved by senior management.
A documented risk assessment of money laundering and terrorist financing risks specific to your business.
A training program for employees, agents or others acting on your behalf.
An effectiveness review every two years to ensure your program continues to meet evolving risks.
Transaction-reporting obligations: Suspicious Transaction Reports (STRs), Large Cash Transaction Reports (LCTRs), Large Virtual Currency Transaction Reports (LVCTRs) for virtual-asset transactions, among others.
How Your Business Should Respond — Partner with Platino Consulting
Building a strong AML program isn’t simply about compliance, it’s about putting controls in place that protect your reputation, strengthen your operations, and give you resilience in a regulated climate. At Platino Consulting, we support businesses across sectors (including precious metals, fintech platforms, real estate businesses) to:
Conduct gap assessments to identify where your current program falls short of FINTRAC expectations.
Draft or update your policies, procedures and training programs to align with regulatory and industry best practice.
Build an implementation roadmap that prioritizes highest-risk areas (client verification, transaction monitoring, reporting workflows).
Build monitoring and review mechanisms and help perform effectiveness reviews or audits.
Prepare you for regulatory examinations by FINTRAC, by strengthening documentation, evidence of training, risk assessments and escalation frameworks.
In a landscape where the enforcement environment is tightening, being proactive is essential. If you’d like to elevate your AML/CTF program, reduce your exposure to financial crimes and regulatory risk, and build a program that works for your business model, contact our team to discuss how we can help you get compliant, stay compliant and operate with confidence.
