AML consultants in Canada for MSBs, PSPs & fintechs
ComplyFactor provides AML advisory services exclusively to non-bank financial businesses across Canada — Money Service Businesses, Payment Service Providers, crypto companies, and fintechs registered with FINTRAC. We do not serve banks. Every engagement is delivered by specialists whose practice is built around the businesses FINTRAC focuses on in enforcement.
Building a program for the first time, preparing for a regulatory review, recovering from a penalty, or refreshing a program that has not been touched in years — you get targeted expert guidance, written deliverables, and fixed-scope pricing with no retainer required.
AML advisory services for Canadian MSBs, PSPs & fintechs
AML advisory covers the work that sits outside the formal audit cycle — building compliance programs, fixing identified gaps, guiding businesses through regulatory scrutiny, and providing expert support when enforcement risk is elevated.
Our practice spans four core areas: program builds for businesses registering with FINTRAC or rebuilding deficient programs; gap analysis and health checks to find weaknesses before regulators do; regulatory review preparation for businesses that have received or anticipate an examination; and post-penalty remediation for businesses that need to demonstrate corrective action following a FINTRAC enforcement decision.
Bill C-12 — March 2026: FINTRAC penalties for serious violations now reach $4,000,000. Businesses that have not had their program reviewed in the past 12 months carry significantly higher regulatory risk than at any point in the history of the PCMLTFA.
Advisory, in practice
Advisory is expert guidance applied to a specific challenge — not a formal assessment of your whole program. A typical engagement delivers one or more of:
- A complete AML program — policies, procedures, risk assessment, training
- A gap report with severity ratings and a prioritised fix list
- Pre-examination preparation scoped to FINTRAC's methodology
- Deficiency-by-deficiency corrective action after a penalty
- Hands-on FINTRAC reporting support — EFTRs, STRs, LVCTRs
Each engagement is scoped before it starts and priced before work begins — written proposal within 48 hours.
When Canadian businesses need AML advisory
Advisory is not a fixed subscription — it is expert guidance applied at the right moment. These are the four situations where Canadian MSBs and PSPs most frequently engage ComplyFactor.
New MSB or PSP registration
Registering with FINTRAC is the start, not the finish. FINTRAC examines newly registered businesses and expects a working compliance program — not a registration-day placeholder. We build the policies, risk assessment, and training framework that survive a first examination.
Preparing for a FINTRAC examination
You have received an examination notice — or you expect one. We close gaps before the examiner finds them: pre-examination gap closure, document organisation, and a team briefing scoped to FINTRAC's methodology for your sector. Unannounced examinations carry no advance-notice requirement.
Post-penalty remediation
Following an Administrative Monetary Penalty or a Mandatory Compliance Agreement, FINTRAC expects documented corrective action by a fixed deadline. We map every cited deficiency to a specific fix and build the documentary evidence FINTRAC accepts as proof of remediation.
Outdated AML program review
If your program has not been refreshed since registration — or predates the March 2026 Bill C-12 changes — it likely no longer reflects your business or the current penalty regime. We review it against FINTRAC's live examination criteria and tell you exactly what to fix first.
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.
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 CanadaWhat our AML advisory engagement covers
Every engagement is scoped to the specific compliance challenge your business faces. Depending on the engagement type, our work covers:
Our AML advisory process
Every engagement follows a consistent methodology — scoped before it starts, delivered by named specialists, and completed with written output your team can act on immediately.
Scoping call — free, 30 minutes
We discuss your business, your regulatory situation, and exactly what you need. No assumptions. No upselling. The call produces a clear scope of work before any cost is agreed.
Written proposal — 48 hours
You receive an engagement letter with a fixed scope, a fixed price, and a delivery timeline before work begins. No retainer required for standalone engagements.
Specialist delivery
Work is delivered by a named senior advisor with direct experience in Canadian AML for MSBs and PSPs — not delegated to junior associates or offshore teams.
Deliverables & handover
Every engagement closes with written output — policies, gap reports, remediation plans, or risk assessments — plus a structured handover call so your team knows exactly what to do next.
Canada's AML enforcement environment
AML obligations for Canadian MSBs and PSPs flow from two primary instruments: the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations (PCMLTFR). FINTRAC administers and enforces both.
The environment changed materially in March 2026 when Bill C-12 received Royal Assent — raising the maximum penalty for serious violations from $100,000 to $4,000,000. For businesses whose programs have not been reviewed recently, the risk calculation under the PCMLTFA has shifted significantly.
- All ComplyFactor engagements are assessed against the current PCMLTFA / PCMLTFR framework
- FINTRAC examinations are active across all sectors — unannounced examinations carry no advance-notice requirement
- Finance and leasing companies became fully subject to FINTRAC oversight
What you receive from an advisory engagement
ComplyFactor does not deliver verbal-only guidance. Every engagement produces written output your team can use, act on, and present to senior management or regulators.
Why Canadian MSBs & PSPs choose ComplyFactor
We work exclusively with the businesses FINTRAC focuses its enforcement on — and we deliver to that reality, not to a bank's playbook.
MSB & PSP specialists — not banks
Our practice is built around MSB and PSP obligations — agent networks, RPAA dual compliance, virtual-currency thresholds, and the specific gaps that generate penalties in your sector.
A named senior advisor on every engagement
Your engagement is led by a CAMS-certified senior AML advisor with direct MSB and PSP experience — named in your engagement letter. No junior associates. No offshore delivery.
Bill C-12 current — not pre-2026 frameworks
Every engagement is assessed against the post-March 2026 enforcement regime. We do not apply guidance written before the penalty structure changed.
Fixed-scope pricing — written before work begins
No retainer. No hourly billing. We agree scope and price before any work starts and provide a written proposal within 48 hours of a scoping call.
Remediation that holds up under scrutiny
We do not fix problems on paper — we fix them in practice. Our remediation is built to satisfy FINTRAC's MCA documentation requirements, not just to produce a report.
