ComplyFactor Reporting

FINTRAC Reporting Automation for Canadian MSBs, Payment Businesses and Casinos

Move from transaction data to validated, reviewed and acknowledged FINTRAC reports through one controlled workflow. Apply report-specific aggregation checks, complete required fields, manage approvals and preserve the reporting history from preparation through submission.

Report-specific validation
Configurable maker–checker approval
24-hour aggregation checks
Submission-status tracking
Report history and activity logs
reporting.complyfactor.com
Acknowledgement received
Sample workflow Β· report reference recorded
Internal review target
04:25:44
The problem

FINTRAC reporting becomes difficult before the report is filed

Most reporting effort is spent upstream of submission: combining transaction data from multiple systems, identifying related transactions, applying report-specific aggregation rules, completing missing client and transaction fields, coordinating approval, tracking deadlines, resolving validation warnings, storing submission evidence and correcting previously filed reports.

Fragmented transaction data

Potentially reportable transactions may be spread across payment systems, branches, customer records, wallet infrastructure and third-party processors.

Manual aggregation

Individually smaller transactions may become reportable when the relevant FINTRAC 24-hour rule is applied β€” and finding those relationships by hand is slow and error-prone.

Incomplete reporting data

A transaction may cross a threshold while required conductor, beneficiary, third-party or account information is still missing from source systems.

Weak approval evidence

Email and spreadsheet-based reporting often makes it difficult to show who prepared, reviewed, approved and corrected a report.

Division of responsibility

Automate the reporting workflow. Keep compliance judgement and accountability with your team. The table below shows exactly where the software's work ends and your compliance function's authority begins.

Platform
Supports or automates
Compliance team
Decides and controls
Transaction import and field mapping
Confirmation that a threshold report is required
Potential threshold-event identification
Resolution of incomplete information
Report-specific aggregation checks
Suspicious-transaction investigation
Required-field validation
Establishing reasonable grounds to suspect
Format and conditional-field checks
STR narrative and supporting context
Workflow routing
Final report approval
Internal reminders
Amendments and corrections
Submission-status tracking
Regulatory decisions
Activity logging and report version history
Overall legal responsibility
Automation supports the reporting process. It does not replace the reporting entity's judgement, approval or legal responsibility.
How it works

Five steps from transaction data to a tracked report

Select a step to see the corresponding screen. Screens shown are illustrative product wireframes.

01
Import and map

Upload structured transaction data or connect approved source systems. Reusable mappings align source information with the relevant FINTRAC report fields.

02
Identify potential reporting events

Apply configurable report-type rules, thresholds and aggregation logic to surface transactions that may require review β€” including report-specific 24-hour aggregation checks.

03
Validate and complete

Check mandatory fields, mandatory-if-applicable information, formatting and conditional data before a report moves toward final approval.

04
Review and approve

Route reports through configurable maker–checker workflows, with comments, returned-for-correction status and recorded sign-off.

05
Submit and track

Where FINTRAC API report submission access is in place for your business, submit reports and capture acknowledgements, warnings and rejected-report responses. Where API access is not yet in place, the workflow produces validated, approved report data for submission through your existing FINTRAC channel, with status recorded against the report.

reporting.complyfactor.com
Report coverage

The FINTRAC reports MSBs, payment businesses and casinos file most

Five live report workflows cover the report types that drive most reporting volume for Canadian MSBs and payment businesses with FINTRAC reporting obligations β€” plus Casino Disbursement Reports for casino reporting entities. Whether a specific report is required in a given situation always depends on your activities and the applicable regulations.

CO designation letter
Written confirmation of your named compliance officer β€” suitable for FINTRAC records and board-level governance documentation.
Written AML policies & procedures
Version-controlled, business-specific policy document β€” built or updated to reflect your current operations, not a generic template.
AML risk assessment
Documented risk-based approach covering customer, product, geographic, and delivery-channel risk β€” PCMLTFR compliant.
Monthly reporting activity log
Written record of all FINTRAC reports filed in the period β€” STRs, EFTRs, LVCTRs β€” with disposition documentation in examination-ready format.
Staff training records
Role-specific training content and completion records for all relevant employees β€” documented to FINTRAC's evidence standard.
Annual program review report
Written annual assessment of your compliance program β€” changes made, rationale documented, effectiveness confirmed.
What's included

What our fractional compliance officer engagement covers

The scope matrix below maps each core compliance obligation to the engagement type it is included in β€” so you know exactly what you're getting before signing anything.

Obligation
New registration
Ongoing retainer
Exam prep
Interim cover
Named CO designation (FINTRAC records)
AML program build / rebuild
FINTRAC reporting (STR, EFTR, LVCTR)
Risk assessment build or update
Annual staff training
Gap analysis & exam preparation
Live compliance management
How we work

Our process β€” from scoping call to named officer

Every engagement follows a consistent four-step process β€” scoped before it starts, delivered by a named senior officer, and structured to meet FINTRAC's standards from day one.

1

Scoping call β€” free, 30 minutes

We assess your FINTRAC registration status, current setup, and business type. No assumptions, no upselling. The call determines whether you need a standalone program build, ongoing retainer, or interim cover.

2

Engagement letter β€” 48 hours

A written engagement letter with fixed scope, named compliance officer, monthly fee, and start date β€” all confirmed before any work begins. No open-ended retainer.

3

CO designation & program review

Your named officer is confirmed in FINTRAC's records within the first week. We review your existing program, identify priority gaps, and begin active management immediately.

4

Active compliance management

Ongoing oversight of reporting obligations, risk assessment, training, and FINTRAC correspondence β€” managed for the term of the engagement, with a written monthly activity log.

The legal basis

FINTRAC's compliance officer requirements β€” PCMLTFA s.9.6

Section 9.6 of the PCMLTFA requires every reporting entity to designate a senior compliance officer responsible for implementing the AML program and ensuring the entity meets its obligations under the Act. FINTRAC's examination framework specifically assesses whether the designated officer:

What FINTRAC assesses

Is named in FINTRAC's registration records with a current, accurate designation
Has genuine authority within the organisation β€” not a junior employee listed in name only
Is demonstrably engaged in the compliance program β€” not just listed on a form
Has maintained the program as the business has changed β€” updated risk assessments, current policies
Has ensured the program has been independently reviewed for effectiveness within the past two years

Bill C-12 (March 2026) raised maximum AMP penalties to $4,000,000 for serious violations. The compliance officer role is now the highest-risk single point of failure in a Canadian MSB's regulatory structure.

PCMLTFA s.9.6
Designates the compliance officer as the accountable individual for program implementation and FINTRAC reporting obligations.
PCMLTFR s.156
(risk-based approach)
The CO is responsible for ensuring the risk assessment is documented, current, and applied in practice β€” not just filed at registration.
PCMLTFR s.165
(training)
Annual training for all relevant staff β€” documented, role-specific, and retained as evidence for FINTRAC examinations.
PCMLTFA s.9.6(2)
(effectiveness review)
The CO must ensure an independent review is conducted at least once every two years. FINTRAC will ask for the most recent audit report.
Bill C-12
(Mar 2026)
Raised maximum AMP penalties to $4,000,000 for serious violations β€” sharpening the accountability attached to the CO role.
Full-time AML compliance officer salary
$110K–$150K
Full-time AML compliance officer salary β€” before CPP, benefits & recruitment
The cost case

Fractional vs full-time

A senior AML compliance officer in Canada typically earns $110,000–$150,000 annually, plus employer CPP contributions, benefits, and the opportunity cost of a 3–6 month recruitment process. For most Canadian MSBs processing under $100M annually, this structure is disproportionate to the compliance function they actually need.

Fractional CO β€” ComplyFactor
Full-time in-house hire
Annual cost
Fixed monthly fee β€” scoped to your actual obligation volume
$110K–$150K + benefits + employer CPP
Time to start
Active within 1 week of engagement letter
3–6 months to recruit, onboard, become effective
FINTRAC exam experience
Direct β€” from multiple active client engagements
Variable β€” depends entirely on the individual
Interim / surge capacity
No gap β€” same officer, same obligations
Requires a separate contractor or agency engagement
Bill C-12 current
Updated immediately β€” all officers on the same framework
Depends on the individual's professional development
Named in FINTRAC records
Within 48 hours of engagement
After hire, onboarding, and FINTRAC record update
The difference

Why Canadian MSBs & PSPs choose ComplyFactor

Active officers carrying live PCMLTFA responsibility β€” named in FINTRAC's records, accountable from week one.

PCMLTFA-native
PCMLTFA-native
FINTRAC examination experience, by design

A named senior officer β€” by name

Your engagement is led by a CAMS-certified senior compliance officer with direct FINTRAC examination experience β€” named in your engagement letter and in FINTRAC's records.

PCMLTFA specialists β€” not generic compliance

Every officer we assign has direct FINTRAC examination experience with MSBs and PSPs. We do not bring bank or insurance backgrounds into Canadian MSB engagements.

Active officers β€” not periodic reviewers

Our compliance officers carry live, ongoing responsibility for your program β€” not a quarterly check-in. Named in FINTRAC records and accountable for active obligations.

Written deliverables on every engagement

Every engagement closes with documented output β€” policies, risk assessments, training records, monthly logs. Nothing verbal-only.

Fixed-scope pricing β€” written before work begins

Monthly fee agreed in writing before the engagement starts. No open retainer, no hourly billing surprises.

Questions

Frequently asked questions β€” fractional compliance officer Canada

What is a fractional compliance officer in Canada?

A fractional compliance officer is a senior AML professional who acts as your designated compliance officer under the PCMLTFA on a part-time or outsourced basis. They carry the same legal responsibilities as a full-time in-house hire β€” named in FINTRAC's records, accountable for your reporting obligations, and actively managing your compliance program β€” at a cost appropriate to your business size and transaction volumes. Most Canadian MSBs and PSPs do not need a full-time compliance officer; a fractional arrangement gives them a qualified officer without the salary, recruitment, and overhead cost of a permanent employee.

Does FINTRAC accept a fractional or outsourced compliance officer?

Yes. The PCMLTFA requires a designated senior officer β€” it does not specify that the person must be a full-time employee of your business. Outsourced and fractional compliance officers are widely used by Canadian MSBs and PSPs. The key requirement is that the individual is genuinely senior, has real authority within your organisation, and is actively engaged in your compliance program β€” not simply listed on a form. ComplyFactor's officers meet all three conditions and are updated in FINTRAC's registration records upon engagement.

How is a fractional compliance officer different from an AML consultant?

An AML consultant provides project-based advisory β€” building a program, conducting a gap analysis, or supporting an examination on a fixed-scope basis. A fractional compliance officer carries ongoing responsibility for your compliance function β€” named in FINTRAC's records, managing live reporting obligations, and owning your compliance calendar. The two roles are complementary, not interchangeable. ComplyFactor provides both, and our scoping call will confirm which your business needs.

What happens to my program if I switch compliance officers?

When a ComplyFactor compliance officer is designated, we document your existing program fully β€” policies, risk assessment, reporting history, and training records. If the engagement ends for any reason, we provide a structured handover package so your next officer, whether internal or external, can take over without a gap in your compliance record. FINTRAC records are updated to reflect the new designation promptly upon a confirmed transition.

How much does a fractional compliance officer cost in Canada?

ComplyFactor prices all compliance officer engagements on a fixed monthly fee β€” not hourly billing. The fee is based on your business type, transaction volumes, and the scope of obligations to be managed. A small MSB with straightforward reporting requires less officer time than a multi-product PSP managing complex monitoring. We provide a written fee proposal within 48 hours of a free scoping call. Contact us at +1 807 806 0444 to discuss your situation.

Can a fractional compliance officer help us prepare for a FINTRAC examination?

Yes β€” FINTRAC examination preparation is one of the most common reasons Canadian MSBs engage a fractional compliance officer. If you've received an examination notice, we can begin a rapid gap analysis immediately, update your designation in FINTRAC's records, organise your documentation, and prepare your team for what an examiner will focus on for your specific business type. For businesses that want to prepare proactively, our ongoing retainer engagements include examination readiness as a standard component.

Get started

Book a free Canada AML consultation

Tell us about your business and we'll confirm which services you need β€” free, no obligation, 30 minutes.

Free, no obligation, 30 minutes
Senior consultant on every engagement
Aligned with PCMLTFA & FINTRAC standards
+1 807 806 0444 Β· Suite 211, 320 Matheson Blvd West, Mississauga, ON

Talk to an AML expert

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