for MSBs & FintechsComplyFactor provides AML consulting and advisory services to Canadian MSBs, FMSBs, fintechs, and payment or virtual currency businesses with applicable FINTRAC obligations. Our work focuses on defined compliance challenges, including regulatory interpretation, gap remediation, examination preparation, and targeted improvements to AML controls.
Need help interpreting a FINTRAC requirement, closing a known compliance gap, preparing for regulatory scrutiny, or responding to an identified deficiency? You receive targeted senior guidance, written deliverables, and a defined scope and price before work begins.
AML advisory addresses specific compliance questions, deficiencies, regulatory events, and implementation challenges that do not require a formal effectiveness review or an ongoing Compliance Officer engagement. Depending on the scope, advisory support can include regulatory interpretation, targeted gap analysis, FINTRAC examination preparation, remediation planning, and implementation support.
Where a business needs a complete FINTRAC compliance program built from the ground up, that work is handled through ComplyFactor’s dedicated compliance program service. AML advisory is intended for targeted support around a defined issue, change, finding, or regulatory event.
Bill C-12 received Royal Assent on March 26, 2026 and strengthened FINTRAC’s administrative monetary penalty framework, including higher maximum penalties and mandatory compliance agreements for prescribed violations occurring after that date. This increases the importance of timely remediation, clear documentation, and current AML controls when compliance deficiencies are identified.
AML advisory provides targeted expert support for a defined compliance issue, regulatory event, or remediation need. Unlike a formal effectiveness review, the engagement is scoped around the specific challenge your business needs to address. A typical engagement may include:
AML advisory is targeted support for a defined compliance issue, regulatory event, remediation need, or material change in the business. Common situations include regulatory preparation, identified deficiencies, enforcement remediation, and targeted updates to an existing compliance framework.
New MSBs and FMSBs may need targeted advice on registration-related compliance requirements, implementation priorities, reporting procedures, governance, and readiness to operate. Where a complete compliance program build is required, that work is handled through ComplyFactor’s dedicated FINTRAC compliance program service.
If your business has received FINTRAC contact or is preparing for an examination, ComplyFactor can help organise requested documentation, identify priority gaps, coordinate remediation, and brief the team on the examination process and applicable compliance requirements.
Following FINTRAC enforcement findings, an Administrative Monetary Penalty, compliance agreement, or compliance order, ComplyFactor can map identified deficiencies to corrective actions, assign remediation priorities and deadlines, and help document the evidence showing how each issue has been addressed.
If your AML framework no longer reflects your current products, customers, technologies, jurisdictions, transaction activity, or regulatory requirements, ComplyFactor can perform a targeted review and identify the updates and remediation priorities that should be addressed.
These two services are frequently confused — and choosing the wrong one wastes time and money. The distinction is straightforward.
Not sure which applies to your situation? Book a free scoping call — we will tell you exactly which service fits, and whether you need both.
Every engagement is scoped to the specific compliance challenge your business faces. Depending on the engagement type, our work covers:
Each AML advisory engagement is scoped around a defined compliance issue or objective. The work begins with understanding the regulatory context and business operations, followed by documented advice, implementation support, and clear written deliverables.
We discuss your business model, applicable FINTRAC obligations, the issue you need to address, existing documentation, and any relevant regulatory deadlines. This allows us to define the appropriate scope before paid work begins.
You receive a written engagement scope setting out the objectives, deliverables, responsibilities, pricing, and expected timeline before work begins. Standalone advisory engagements do not require an ongoing retainer.
The engagement is led by a named AML advisor with relevant Canadian compliance experience. Advice and deliverables are developed around the applicable FINTRAC requirements, the agreed scope, and your business’s actual operations.
At completion, you receive the written deliverables defined in the engagement scope, together with a handover covering findings, recommended actions, responsibilities, priorities, and any relevant implementation or regulatory deadlines.
Canadian reporting entities subject to FINTRAC oversight have obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations. The specific requirements that apply depend on the reporting-entity sector and the activities the business conducts.
Bill C-12 received Royal Assent on March 26, 2026 and strengthened FINTRAC’s administrative monetary penalty framework. Among the changes are increased maximum penalties, mandatory compliance agreements for prescribed violations, and compliance orders as an additional enforcement tool.
Written AML advisory deliverables tailored to the agreed scope — designed to support implementation, remediation, management reporting, or FINTRAC preparation where applicable.
ComplyFactor provides focused AML advisory for non-bank financial businesses that need practical support with FINTRAC requirements, regulatory change, remediation, examination preparation, and compliance implementation.

Our Canadian advisory work focuses on MSBs, FMSBs, fintechs, and payment or virtual currency businesses with applicable FINTRAC obligations, including registration, reporting, risk management, compliance controls, remediation, and regulatory change.
Your engagement is led by a named CAMS-certified AML advisor with relevant Canadian compliance experience who works directly with the agreed scope, applicable requirements, business context, and final deliverables.
Advisory work considers the PCMLTFA, associated Regulations, and current FINTRAC guidance relevant to the engagement, including legislative changes that came into force on March 26, 2026.
For standalone advisory engagements, the scope, deliverables, pricing, responsibilities, and expected timeline are documented before paid work begins, so your team understands the engagement before proceeding.
Remediation support connects each identified deficiency to practical corrective actions, responsible owners, target dates, implementation steps, and supporting documentation appropriate to the regulatory issue being addressed.
An AML consultant provides targeted guidance on the FINTRAC and PCMLTFA requirements relevant to a business and a defined compliance issue. Support can include gap analysis, regulatory interpretation, examination preparation, risk-assessment updates, reporting support, remediation planning, and improvements to specific policies or controls. Unlike a formal effectiveness review, advisory work is scoped around the particular issue the business needs to address.
Yes. AML advisory can support remediation following FINTRAC findings, an Administrative Monetary Penalty, a compliance agreement, or a compliance order. ComplyFactor can map identified deficiencies to corrective actions, establish responsibilities and target dates, support implementation, and organise documentation showing the steps taken to address the findings.
Under the framework introduced by Bill C-12, prescribed violations committed after March 26, 2026 require mandatory compliance agreements, and FINTRAC may also use compliance orders as an enforcement tool.
Start times depend on the urgency, scope, documentation available, and advisor capacity. Regulatory notices, examination requests, and enforcement-related matters can be prioritised where possible. Each engagement begins with an initial scoping discussion followed by confirmation of the proposed scope, deliverables, pricing, and timeline before paid work begins.
External AML advisory is not a separate legal requirement simply because an MSB is small or newly registered. However, a newly registered MSB must still establish and implement the FINTRAC compliance requirements applicable to its activities. Advisory support can be useful where the business needs help interpreting those requirements, identifying implementation gaps, preparing for regulatory contact, or updating specific controls.
AML advisory pricing depends on the scope, complexity, urgency, existing documentation, and the specific compliance issue being addressed. Standalone engagements are scoped before work begins, with the deliverables, pricing, responsibilities, and expected timeline set out in writing. Contact ComplyFactor to discuss the required scope.
Yes. ComplyFactor provides AML advisory services remotely to businesses across Canadian provinces and territories. FINTRAC obligations arise under the federal PCMLTFA framework, although other federal or provincial requirements may also apply depending on the business model and activities. The advisory scope is defined around the requirements relevant to the engagement.
Tell us about your business, the AML issue you need to address, and any relevant FINTRAC deadlines or regulatory contact. We’ll use the consultation to understand the situation and define the appropriate next step.