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 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 is expert guidance applied to a specific challenge — not a formal assessment of your whole program. A typical engagement delivers one or more of:
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.
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.
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.
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.
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.
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:
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.
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.
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.
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.
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.
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.
A complete, documented compliance framework — every component formatted for FINTRAC examination and editable for ongoing maintenance.
We work exclusively with the businesses FINTRAC focuses its enforcement on — and we deliver to that reality, not to a bank's playbook.

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.
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.
Every engagement is assessed against the post-March 2026 enforcement regime. We do not apply guidance written before the penalty structure changed.
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.
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.
An AML consultant provides expert compliance guidance specific to your business and regulatory situation — building or rebuilding AML programs, identifying gaps before a regulatory review, preparing businesses for FINTRAC scrutiny, and managing corrective action after a penalty. Unlike an independent audit, advisory work is targeted at your specific challenge rather than producing a formal assessment of your entire program.
Yes — post-penalty remediation is one of our most common engagements. Under Bill C-12 (March 2026), Mandatory Compliance Agreements are now statutory. Businesses that receive an Administrative Monetary Penalty must enter into a compliance agreement and demonstrate documented corrective action by a fixed deadline. Failure to comply with a compliance order can result in additional penalties of up to $30,000,000 or 3% of global revenue. ComplyFactor maps every cited deficiency to a specific corrective action and builds the documentary evidence FINTRAC accepts as proof of remediation.
For urgent situations — businesses that have received a regulatory notice or penalty — we can begin producing output within 48 hours of engagement. For planned work such as program builds and gap analyses, we typically commence within one to three business days. All engagements begin with a free 30-minute scoping call and a written proposal before any work begins.
Yes — and they often need it most. Many small MSBs register with FINTRAC using minimal documentation and believe their obligations are complete. FINTRAC examines newly registered businesses and expects a working compliance program — not a registration-day placeholder. We regularly work with smaller and newly registered businesses to build programs that survive an examination, not just satisfy the registration checklist.
We use fixed-scope pricing — not hourly billing or open-ended retainers. Cost depends on engagement type and complexity: a gap analysis for a straightforward MSB is scoped and priced differently from a full program build for a multi-product PSP. We provide a written quote within 48 hours of a free 30-minute scoping call. Contact us at +1 807 806 0444.
Yes. We provide AML advisory services to businesses in all Canadian provinces and territories. FINTRAC regulation is federal — our advisory framework applies consistently regardless of where your business operates. Most engagements are delivered remotely; we do not require on-site presence for gap analyses, program builds, or post-penalty remediation.
Tell us about your business and we'll confirm which services you need — free, no obligation, 30 minutes.