AML Support Canada | Outsourced CAMLO + FINTRAC Compliance

Buying or registering a money services business is the first step. Keeping it compliant is the ongoing challenge — and in 2026, that challenge carries consequences that can end your business overnight.

FINTRAC revoked over 86 MSB registrations in Q1 2026 alone, with 51 cancelled in a single day on March 24. Approximately 83% of those entities still had valid, unexpired registrations. FINTRAC did not wait for them to lapse — it actively determined they were no longer eligible and pulled them. Then Bill C-12 received Royal Assent on March 26, 2026, raising administrative monetary penalties to $20 million for very serious violations — or 3% of gross global revenue, whichever is greater.

Your MSB registration is only as safe as the compliance program behind it. Ongoing AML support is not optional overhead — it is operational infrastructure.

Get ongoing AML support for your MSB — WhatsApp, Telegram, email, phone, or book a consultation.

Why Ongoing AML Support Is Essential

FINTRAC does not check your compliance once and move on. It conducts risk-based examinations throughout the lifecycle of your MSB registration. Compliance is not a one-time project — it is an ongoing obligation that evolves as regulations change, your risk profile shifts, and your business activities expand.

The regulatory landscape in 2026 makes this especially clear. FINTRAC’s Q1 enforcement wave targeted MSBs with zero or near-zero transaction reporting — both dormant registrants and operating businesses that failed to file required reports. The pattern moved backward through registration cohorts, revoking entities registered as far back as 2020. If your MSB is registered and not actively maintaining its compliance obligations, the enforcement data shows you are at risk.

Bill C-12 introduced a new very serious violation category: failure to ensure your compliance program is “reasonably designed, risk-based and effective.” This is not aspirational language. It is a specific, enforceable standard with a $20 million penalty ceiling. The word “effective” is the critical addition — having a compliance program on paper is no longer sufficient. It must demonstrably work.

On top of FINTRAC obligations, the October 2025 regulatory amendments added new agent and mandatary supervision requirements. MSBs using third-party agents must now actively oversee their compliance conduct. And for businesses that also operate as payment service providers, the Retail Payment Activities Act (RPAA) adds a second regulatory layer under the Bank of Canada.

The two-year effectiveness review cycle, annual training requirements, ongoing transaction monitoring, and continuous regulatory updates all demand sustained attention. Miss any of these, and your MSB becomes exactly the kind of target FINTRAC demonstrated it is willing to act against.

For a deeper understanding of what FINTRAC requires, see our AML/CTF compliance guide and our analysis of 2026 regulatory changes affecting MSBs.

Our Ongoing AML Support Services

Outsourced Compliance Officer (CAMLO)

Not every MSB has a qualified Chief AML Officer on staff — and FINTRAC does not require you to. We provide fractional and outsourced CAMLO services for MSBs that need expert compliance leadership without the cost and overhead of a full-time hire.

FINTRAC permits outsourcing of the compliance officer role. There is no requirement that your CAMLO be an employee or be physically located in Canada. The requirement is that your officer is knowledgeable about Canadian AML/ATF obligations, has sufficient authority within your organization, and is accessible to FINTRAC when needed.

Our outsourced CAMLO services include program oversight, regulatory liaison, and acting as FINTRAC’s designated point of contact for your business. Your CAMLO oversees Suspicious Transaction Report (STR) filings, Large Cash Transaction Report (LCTR) processing, sanctions screening protocols, and all regulatory correspondence.

This is particularly valuable for smaller operations, newly acquired ready-made MSBs, and foreign-owned entities (FMSBs) that need Canadian compliance expertise without the expense of a full-time compliance hire. For a comparison of compliance-related costs, see our MSB costs guide.

Transaction Monitoring and Reporting

Ongoing transaction monitoring is the operational backbone of AML compliance. We provide continuous review of your transactions against risk indicators, thresholds, and regulatory triggers:

Suspicious Transaction Reports (STRs) — identification, investigation, filing, and documentation of transactions that raise suspicion of money laundering or terrorist financing, regardless of dollar amount
Large Cash Transaction Reports (LCTRs) — monitoring and reporting all cash transactions of $10,000 or more received in a single transaction or in multiple transactions within 24 hours
Electronic Funds Transfer Reports (EFTRs) — reporting cross-border electronic fund transfers of $10,000 or more, whether sent or received
Terrorist Property Reports — sanctions screening against OFSI consolidated lists and immediate reporting of any property owned or controlled by a listed person or entity

Every report must be filed within FINTRAC’s prescribed timelines, with proper documentation and record retention. Missed or late filings are exactly the kind of compliance gaps that triggered the Q1 2026 revocation wave — entities with zero reporting history were the primary targets.

For more on reporting obligations, see our AML compliance guide.

Regulatory Updates and Policy Maintenance

AML regulations do not stand still. The PCMLTFA, its associated regulations, and FINTRAC’s guidance documents are amended regularly. When the rules change, your policies and procedures must change with them.

We proactively monitor all regulatory developments relevant to your MSB and update your compliance program accordingly. This includes PCMLTFA amendments, new FINTRAC guidance releases, changes to sanctions lists, and shifts in FINTRAC’s enforcement priorities.

The 2026 regulatory environment illustrates why this matters. Bill C-12’s penalty restructuring, the new “reasonably designed, risk-based and effective” compliance standard, and potential interactions between FINTRAC and the Bank of Canada’s RPAA supervision programme all require policy updates. MSBs dealing in virtual currencies face additional complexity from evolving crypto regulation in Canada.

Rather than learning about regulatory changes after they take effect — or worse, during a FINTRAC examination — our clients receive updates and policy revisions proactively.

Staff Training and Education

FINTRAC requires every MSB to maintain an ongoing AML/ATF training program. This is not a one-time onboarding exercise — it is a continuous obligation:

Annual refresher training covering AML/ATF obligations, red flag indicators, reporting procedures, and regulatory updates
New employee onboarding ensuring every staff member understands their compliance responsibilities from day one
Role-specific training for agents, mandataries, customer-facing staff, and anyone involved in transaction processing or client onboarding
Training documentation and record-keeping — FINTRAC expects to see evidence that training occurred, who attended, what was covered, and when

The October 2025 amendments added new agent supervision requirements, making training for third-party agents and mandataries particularly important. If your MSB uses agents, their compliance knowledge is now explicitly your responsibility.

Effectiveness Reviews

Every two years, FINTRAC requires MSBs to conduct an independent assessment of their entire compliance program. This is not an internal self-evaluation — it must be conducted by someone with sufficient independence and expertise to provide an objective assessment.

Our effectiveness review service covers the full scope of your compliance program: policies and procedures, risk assessment methodology, transaction monitoring effectiveness, reporting accuracy and timeliness, training program adequacy, and record-keeping completeness.

The deliverable is a documented assessment with findings, risk ratings, and a remediation plan for any identified gaps. This document is exactly what FINTRAC examines during compliance reviews — having a thorough, professionally conducted effectiveness review on file is one of the strongest defenses against enforcement action.

Under Bill C-12’s new “reasonably designed, risk-based and effective” standard, the effectiveness review is no longer just a regulatory checkbox. It is direct evidence of whether your compliance program meets the enforceable standard — and failure to meet that standard now carries a $20 million penalty ceiling.

For more on what goes into a compliance program, see our guide on MSB compliance program contents.

FINTRAC Examination Preparation

FINTRAC conducts risk-based compliance examinations with no fixed schedule. Higher-risk MSBs, newly registered entities, and businesses flagged through reporting analysis may be examined at any time. When FINTRAC contacts you, preparation is everything.

Our examination preparation service includes:

Pre-examination readiness assessment — a comprehensive review of your compliance posture before FINTRAC arrives
Document and record organization — ensuring all policies, procedures, risk assessments, training records, and transaction reports are current, complete, and retrievable
Mock examination walkthrough — simulating FINTRAC’s assessment methodology so you know what to expect and how to respond
Post-examination remediation — if FINTRAC identifies deficiencies, we develop and implement a remediation plan to address findings before they escalate to penalties or revocation

Given the 86+ revocations in Q1 2026, examination preparation is no longer an abstract precaution. It is a concrete operational need.

AML Support for Ready-Made MSB Buyers

If you have purchased a ready-made MSB, you already have a registered entity with an existing compliance program. That program is a starting point — but it must be customized to your specific business activities, risk profile, and operational structure before you begin transacting.

Our AML support for ready-made MSB buyers covers the transition from purchase to full operational compliance:

Compliance program customization — adapting the existing AML program to your specific activities, whether you are operating in foreign exchange, money transfer, virtual currency, crowdfunding, money orders, or payment services
Immediate operational readiness — ensuring your compliance infrastructure is in place so you can begin transacting without delay
Seamless handoff — the same team that supports the purchase process transitions directly into ongoing compliance support

The advantage of buying a ready-made MSB is speed. The advantage of combining it with ongoing AML support is certainty — certainty that your compliance program is active, maintained, and defensible from day one.

For a complete overview of the transition process, see our guides on what happens after buying an MSB and what to look for in MSB providers.

Why Choose Our AML Support

We are MSB specialists. Not a generic financial compliance firm applying bank-level frameworks to small money services businesses. Not a law firm billing hourly for regulatory advice. We work exclusively with Canadian MSBs, and our compliance support reflects the operational realities of this specific sector.

All-permissions expertise. Our MSBs come with all FINTRAC permission categories — foreign exchange, money transfer, virtual currency, crowdfunding, money orders, and payment services. We understand the compliance nuances of each activity type and tailor our support accordingly.

Integrated service. The same team that designs your compliance program maintains it. There is no handoff to a different provider, no knowledge gaps, no re-learning your business every time a question arises.

Ready-made MSB continuity. If you purchased your MSB through us, ongoing AML support is a seamless continuation of an existing relationship. Your compliance history, risk profile, and program documentation are already in our hands.

Dual MSB + RPAA capability. For businesses that also require registration under the Retail Payment Activities Act, we provide integrated compliance support covering both FINTRAC and Bank of Canada obligations. Our RPAA application service handles the registration; our AML support keeps both frameworks running.

Frequently Asked Questions

What does ongoing AML support include for a Canadian MSB?

Ongoing AML support covers the full range of compliance obligations FINTRAC requires after registration: outsourced compliance officer (CAMLO) services, transaction monitoring and reporting (STRs, LCTRs, EFTRs, terrorist property reports), regulatory updates and policy maintenance, annual staff training, two-year effectiveness reviews, and FINTRAC examination preparation. The scope is tailored to your MSB’s specific activities and risk profile.

Can I outsource my MSB compliance officer to a third party?

Yes. FINTRAC permits outsourcing of the compliance officer role. There is no regulatory requirement that your CAMLO be an in-house employee or be physically located in Canada. The requirements are that the officer is knowledgeable about Canadian AML/ATF obligations, has sufficient authority within your organization, and is accessible for FINTRAC communications. Legal responsibility for compliance remains with the MSB.

How often does FINTRAC examine MSBs?

There is no fixed examination schedule. FINTRAC conducts risk-based examinations, meaning higher-risk MSBs, newly registered entities, and businesses with reporting anomalies may be examined sooner and more frequently. The Q1 2026 enforcement wave demonstrated that FINTRAC is also willing to revoke registrations based on compliance analysis without necessarily conducting a full on-site examination first.

What happens if FINTRAC finds compliance deficiencies?

Consequences range from guidance letters and compliance agreements to administrative monetary penalties (AMPs) and registration revocation. Under Bill C-12, effective March 26, 2026, AMPs can reach $40,000 for minor violations, $4 million for serious violations, and $20 million for very serious violations. The cumulative cap for multiple violations is the greater of $20 million or 3% of gross global revenue. In Q1 2026, FINTRAC revoked 86+ MSB registrations — demonstrating it is willing to use its most severe enforcement power.

Do I need AML support if I bought a ready-made MSB with a compliance program?

Yes. The compliance program included with a ready-made MSB is a foundation, but it must be customized to your specific business activities, client base, geographic exposure, and risk profile. Beyond customization, the program requires ongoing maintenance — transaction monitoring, reporting, annual training, policy updates, and two-year effectiveness reviews. A compliance program that is not actively maintained will not meet FINTRAC’s “reasonably designed, risk-based and effective” standard.

How much does outsourced AML support cost for an MSB?

Costs depend on several factors, including the scope of MSB activities, transaction volumes, number of agents or employees, and the level of support required. We tailor our AML support packages to each client’s operational needs. Contact us for a detailed quote — WhatsApp, Telegram, email, phone, or book a consultation.

Protect Your MSB Registration

Your MSB registration is a business asset. The compliance program behind it determines whether that asset is protected or at risk. With 86+ registrations revoked in a single quarter and penalty ceilings raised to $20 million, ongoing AML compliance is not a cost centre — it is the cost of staying in business.

Whether you are launching a newly purchased ready-made MSB, operating an established money services business, or expanding into new activity types, our ongoing AML support keeps your compliance program current, defensible, and aligned with FINTRAC’s expectations.

Talk to our team today — WhatsApp, Telegram, email, phone, or book a consultation.