Understanding FINTRAC’s Compliance Program Requirements
Building a Strong FINTRAC Compliance Program: Key Requirements & Best Practices
FINTRAC, Canada’s financial intelligence unit, mandates that all “reporting entities” (such as financial institutions, MSBs, real estate businesses, and others) establish and maintain a formal anti-money laundering (AML) compliance program. Without it, firms risk regulatory penalties, reputational damage, or worse. Understanding and implementing this program properly is therefore critical for sustainable compliance.
What Does FINTRAC Require?
According to FINTRAC’s official Compliance Program Requirements guidance, a compliant program must include:
Appointing a Compliance Officer
Every reporting entity needs a designated compliance officer responsible for implementing and overseeing the AML program. This person must have enough authority, access to senior management, and knowledge of the business’s structure and ML/TF risks.Written Policies & Procedures
Detailed, up-to-date policies and procedures are required, covering customer identification (KYC), ongoing monitoring, record-keeping, transaction reporting, and more. These policies must be approved by a senior officer and tailored to your business.Risk Assessment
Your business must perform a documented AML risk assessment of its money-laundering, terrorist-financing, and sanctions risks, taking into account clients, services, delivery channels, and geographies.Training Program
You must develop and maintain a written, ongoing AML training plan for all relevant staff, including agents or mandatary persons. This program needs to be updated regularly to reflect evolving risk. It needs to be administered on an annual basis.Effectiveness Review
At least every two years, the AML compliance program must be reviewed (internally or externally) to test its effectiveness. This includes policies, risk assessment, training, and control activities.
Why Many Businesses Struggle
Despite the clarity of FINTRAC’s guidance, many businesses struggle to build or maintain an effective program:
They underestimate the complexity of their risk profile (especially if they operate across multiple products or geographies).
Their compliance policies are too generic and not tailored to their business model.
Training is often ad hoc or poorly documented, which raises red flags during regulatory exams.
Risk assessments go stale, or the two-year review plan is neglected.
Compliance officers lack capacity, especially in smaller firms, to independently manage program effectiveness.
This is where Platino Consulting can help. Our team specializes in designing and implementing FINTRAC-compliant AML programs that are not just “tick-the-box,” but truly risk-based, defensible, and operational. We deliver:
A tailored risk assessment and mitigation plan
Written policies and procedures aligned with your business and FINTRAC rules
A scalable training program with documented evidence of completion
Independent review (or mock FINTRAC exam) to test and refine your program
How to Get Started
Schedule a Compliance Gap Assessment — We analyze your current AML maturity against FINTRAC’s requirements.
Develop a Roadmap — We build a phased implementation plan that prioritizes risk and resource constraints.
Execute & Train — We help you roll out policies, deliver training, and embed AML into your operations.
Review & Improve — Through regular effectiveness reviews, we ensure your program evolves with your business and regulatory landscape.
If you want to build a FINTRAC compliance program that protects your organization, reduces risk, and supports sustainable growth, contact us for a confidential consultation.
