AML consultants in Canada for MSBs & Fintechs

ComplyFactor 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.

MSB, FMSB & fintech focus
Current FINTRAC requirements
Fixed-scope pricing
No retainer required

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Our advisory service

AML Consulting & Advisory Services for Canadian MSBs

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.

Advisory, in practice

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:

Targeted compliance-program updates — policies, procedures, risk assessment, training, or specific control improvements
A targeted gap analysis with documented findings, severity ratings, and a prioritised remediation plan
FINTRAC examination preparation, including document organisation, gap review, and team briefing
Deficiency-by-deficiency remediation planning and implementation support following regulatory findings or enforcement action
FINTRAC reporting support — STRs, LCTRs, EFTRs and LVCTRs where applicable
Each engagement is scoped before work begins, with the objectives, deliverables, responsibilities, timeline, and pricing documented in a written proposal.
When advisory helps

When Canadian businesses need AML advisory

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.

Scenario 01

New MSB or PSP registration

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.

Scenario 02

Preparing for a FINTRAC examination

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.

Scenario 03

Post-penalty remediation

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.

Scenario 04

Outdated AML program review

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.

Choose the right service

Do you need AML advisory or an AML audit?

These two services are frequently confused — and choosing the wrong one wastes time and money. The distinction is straightforward.

What it is
Targeted guidance to interpret requirements, address gaps, support remediation, or strengthen specific controls.
Structured effectiveness review that tests whether the required compliance-program elements are working in practice.
Required by law?
No — advisory is used when targeted expert support is needed.
A two-year effectiveness review is required at least every two years for reporting entities subject to the compliance-program requirements.
Trigger
Defined compliance issue, regulatory change, identified gap, examination preparation, or remediation need.
Required two-year effectiveness-review cycle or another need for formal program testing.
Output
Targeted written advice, gap analysis, remediation plan, updated controls, or other scoped compliance deliverables.
Documented effectiveness-review report covering the scope, testing performed, findings, deficiencies, recommendations, and action plans where applicable.
Typical order
Used when targeted guidance, preparation, or remediation is needed.
Conducted when a formal effectiveness review is required or separately scoped.

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.

Visit AML Audit Canada
Scope of work

Every engagement is scoped to the specific compliance challenge your business faces. Depending on the engagement type, our work covers:

#
Advisory area
What it means for your business
01
Targeted compliance program support
Targeted updates or improvements to specific elements of an existing FINTRAC compliance program, including policies and procedures, risk assessment, training, governance, monitoring, or reporting controls. Complete program builds are handled through our dedicated FINTRAC Compliance Program service.
02
AML risk assessment review & refresh
Review and refresh of the AML risk assessment to reflect current clients and business relationships, products and services, delivery channels, geographic exposure, new technologies, transaction activity, sanctions-evasion risks, and other factors relevant to the business.
03
Gap analysis & compliance health check
Targeted review of selected compliance-program elements and applicable FINTRAC requirements, producing documented findings, identified gaps, and a prioritised remediation plan based on the scope of the engagement.
04
FINTRAC examination preparation
Preparation support for a FINTRAC examination, including document organisation, review of requested materials, identification of priority gaps, remediation coordination, and briefing relevant personnel on the examination process and applicable requirements.
05
Regulatory findings & enforcement remediation
Deficiency-by-deficiency remediation planning following FINTRAC findings or enforcement action, including corrective-action mapping, implementation support, responsibility assignment, target dates, and documentation of the steps taken to address identified issues.
06
FINTRAC reporting support
Guidance on FINTRAC reporting obligations, including STRs, LCTRs, EFTRs and LVCTRs where applicable. Support can cover reportability, thresholds and aggregation rules, filing timelines, internal escalation, recordkeeping, and submission procedures relevant to the business.
07
Ongoing AML advisory support
Periodic access to a named AML advisor for defined compliance questions, regulatory changes, implementation support, and emerging issues. This advisory support complements the business’s internal compliance function and does not replace the appointed Compliance Officer where one is required.
How we work

Our AML advisory process

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.

1

Scoping call — free, 30 minutes

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.

2

Written proposal & scope

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.

3

Specialist delivery

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.

4

Deliverables & handover

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.

Maximum AMP for serious violations
$4,000,000
Maximum AMP for serious violations — Bill C-12, March 2026
The regulatory backdrop

Canada’s FINTRAC Regulatory Framework

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.

Advisory work is scoped against the FINTRAC requirements and guidance applicable to the business and issue being addressed.
FINTRAC uses a risk-based supervisory approach, and the scope of an assessment can vary based on the business and the compliance risks being examined.
Financing and leasing entities became subject to applicable FINTRAC obligations effective April 1, 2025.
PCMLTFA
Canada’s primary federal AML/ATF legislation. It establishes reporting-entity obligations and FINTRAC’s compliance and enforcement framework.
PCMLTFR
(Regulations)
Regulations supporting the PCMLTFA that set detailed requirements for matters such as client identification, records, prescribed transactions, reporting, and other compliance obligations.
Bill C-12
(Mar 2026)
Amended the PCMLTFA framework in March 2026, including increased administrative monetary penalty limits, mandatory compliance agreements for prescribed violations, and new compliance-order powers.
FINTRAC guidance
FINTRAC publishes operational and sector-specific guidance explaining how reporting entities should meet applicable obligations. Advisory work should use the guidance relevant to the business and issue being addressed.
Deliverables

What you receive from an advisory engagement

Written AML advisory deliverables tailored to the agreed scope — designed to support implementation, remediation, management reporting, or FINTRAC preparation where applicable.

Targeted policy & procedure updates
Targeted, version-controlled updates to policies and procedures based on the agreed advisory scope, applicable FINTRAC requirements, and the business’s actual activities, risks, processes, and controls.
AML risk assessment review & refresh
Review and update of relevant AML risk factors, ratings, rationale, and enhanced measures to reflect current clients, products and services, delivery channels, geographic exposure, technologies, and other material business changes.
Customer risk framework review
Review or refinement of customer and business-relationship risk criteria, documented risk indicators, rating logic, escalation rules, and enhanced measures for higher-risk situations where applicable.
Transaction monitoring advisory
Targeted review of transaction-monitoring rules, scenarios, red flags, alert handling, escalation procedures, investigation records, and suspicious-transaction reporting workflows relevant to the agreed scope.
AML training review & update
Review or update of role-appropriate AML training materials, training-plan requirements, relevant regulatory topics, escalation procedures, and records used to document training delivery and completion.
Governance & compliance oversight support
Targeted governance support covering Compliance Officer responsibilities, authority, management reporting, escalation routes, ownership of remediation actions, and planning for applicable compliance reviews.
Compliance action plan & calendar
A prioritised schedule of relevant remediation actions, regulatory deadlines, reporting obligations, document updates, training activities, and review dates identified through the advisory engagement.
The difference

Why Canadian MSBs Choose ComplyFactor for AML Advisory

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.

MSB & PSP only
Canadian non-bank AML advisory

Focused on MSBs, FMSBs & fintechs

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.

A named senior advisor on every engagement

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.

Current FINTRAC regulatory requirements

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.

Fixed-scope pricing — written before work begins

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.

Practical, documented remediation support

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.

Questions

Frequently asked questions — AML consultant Canada

What does an AML consultant do in Canada?

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.

Can an AML consultant help after a FINTRAC penalty?

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.

How quickly can an advisory engagement begin?

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.

Do small or newly registered MSBs need AML advisory?

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.

What is the cost of AML advisory services in Canada?

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.

Do you work with businesses across all Canadian provinces?

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.

Get started

Book a Free AML Advisory Consultation

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.

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

Talk to an AML expert

Thank you. Your message has been received — we'll be in touch within one business day.
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