Why Businesses Need Expert AML Support: Key Takeaways from FINTRAC’s Latest Guidance

Canada’s Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) landscape is evolving fast, and FINTRAC’s new educational content underscores just how high expectations have become for reporting entities. More sectors are being brought under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), supervisory methods are more data-driven, and enforcement is increasingly assertive.

For many businesses, this creates a real challenge: your operations must keep up with a regulatory environment that is constantly intensifying, or you risk deficiencies, action plans, or costly administrative monetary penalties (AMPs).

This is where partnering with Platino Consulting becomes invaluable. Below, we break down FINTRAC’s key messages.

FINTRAC’s Mandate Is Clear and Compliance Expectations Are Rising

FINTRAC has two core responsibilities:

1. Ensure compliance with the PCMLTFA and associated regulations across all reporting entity sectors; and

2. Generate actionable financial intelligence for law enforcement and national security partners.

This dual mandate means FINTRAC is both a regulator and an intelligence agency and your compliance program directly impacts both sides of their work.

FINTRAC’s supervisory frameworks now focus heavily on:

• Risk-based oversight

• Early intervention

• Targeted examinations

• Firm consequences for repeated or serious deficiencies

Businesses that fail to keep their compliance programs current often find themselves facing corrective action plans, long examination cycles, and potential AMPs.

Understanding Your Obligations: The Foundation of Compliance

FINTRAC outlines six major compliance pillars, all of which must be tailored, documented, and defensible:

1. A Comprehensive Compliance Program

Every reporting entity must maintain:

• A knowledgeable compliance officer

• Up-to-date, tailored AML/ATF policies and procedures

• A documented ML/TF risk assessment

• A training program

• A biennial independent effectiveness review

Weakness in any of these areas is one of the most common reasons FINTRAC identifies deficiencies.

2. Know Your Client (KYC) Obligations

Businesses must:

• Verify the identity of individuals and entities using prescribed methods

• Obtain beneficial ownership information

• Identify third-party involvement

• Conduct ongoing monitoring

• Screen for politically exposed persons (PEPs), heads of international organizations (HIOs), and high-risk associates

FINTRAC’s emphasis on sanctions evasion further raises the bar, requiring enhanced vigilance and updated procedures.

3. Mandatory Reporting Requirements

Reporting entities must submit:

• Suspicious Transaction Reports (STRs) — a key intelligence tool

• Large Cash Transaction Reports (LCTRs)

• Large Virtual Currency Transaction Reports (LVCTRs)

• Terrorist Property and Listed Person reports

• Sanctioned property reports

Incorrect, inconsistent, or late reporting is a major driver of penalties.

4. Record Keeping

Every KYC step, transaction, decision, and rationale must be documented properly, consistently, and in accordance with the regulations.

5. Registration Requirements

MSBs and FMSBs must register and maintain accurate information or risk being delisted or flagged for examination.

6. Ministerial Directives & Countermeasures

Businesses must comply with special measures imposed on high-risk jurisdictions. Failure to implement directives is a serious offence.

The Often-Ignored Requirement: A Strong, Defensible Risk Assessment

FINTRAC repeatedly stresses that a risk assessment is not optional and not a checklist exercise.

Businesses must evaluate:

• Client types and behaviours

• Geographic exposure

• Products and delivery channels

• New technologies

• Other unique business risk factors

Crucially, FINTRAC now expects reporting entities to align their risk assessments with Canada’s National Risk Assessment, and update their programs when national risks evolve.

Most risk assessments we review for new clients contain one or more critical gaps, such as:

• Missing prescribed risk factors

• No written rationale for risk ratings

• Outdated information

• Misalignment with current FINTRAC guidance

• No connection between risks and controls

These gaps are exactly what lead to findings during examinations.

Why Businesses Fail: FINTRAC’s Most Common Deficiencies

Across sectors, FINTRAC identifies recurring issues:

• Outdated or generic policies and procedures

• Risk assessments missing required elements

• Insufficient training programs

• Inaccurate or incomplete STRs

• Failure to identify beneficial owners

• Weak ongoing monitoring practices

• Ineffective or missing biennial reviews

Each deficiency increases a business’s risk rating, making future examinations more intensive and more likely to result in enforcement.

Why Work with Platino Consulting?

Regulatory expectations have outpaced what most internal teams can reasonably maintain, especially MSBs, real estate professionals, dealerships, securities registrants, fintechs, dealers in precious metals and stones, and other increasingly targeted sectors.

Platino Consulting helps you:

1. Prevent costly penalties

We identify gaps early and implement corrective actions before FINTRAC flags them.

2. Build a defensible compliance program

Every control, workflow, and decision is documented in line with regulatory expectations.

3. Strengthen KYC, reporting, and monitoring

We help implement practical processes that meet requirements without disrupting business.

4. Stay ahead of regulatory changes

Sanctions, risk assessments, and national guidance now shift rapidly. We ensure you stay compliant.

5. Prepare for (or recover from) FINTRAC examinations

We support you through pre-exam preparation, responses, remediation plans, and communications.

6. Improve operational efficiency

Good compliance is not only a legal requirement—it enhances client trust, prevents fraud, and reduces long-term costs.

Protect Your Business Before FINTRAC Comes Knocking

FINTRAC’s message is clear: AML expectations are increasing, and compliance failures will have consequences.

Whether you’re an MSB, dealer in precious metals and stones, securities dealer, real estate brokerage, fintech, or other reporting entity, expert AML support is the most effective way to reduce risk and keep your program aligned with regulatory developments.

Platino Consulting specializes in helping businesses:

• Implement strong compliance programs

• Conduct robust risk assessments

• Build KYC and monitoring frameworks

• Prepare for FINTRAC examinations

• Create effective training programs

• Strengthen reporting processes

If your business wants to avoid penalties and operate with confidence, now is the time to act.

Contact Platino Consulting today to set up a consultation call.