Independent AML audit services in Canada
ComplyFactor provides independent AML audit services to businesses across Canada — including Money Service Businesses, Payment Service Providers, fintechs, and Virtual Asset Service Providers registered with FINTRAC. Our effectiveness reviews are conducted by compliance specialists with direct experience in Canadian AML regulation.
Every regulated business in Canada must demonstrate that its AML program works in practice, not just on paper. ComplyFactor tests exactly that — and delivers a clear, written remediation roadmap your team can act on immediately.
AML audit services for Canadian MSBs, PSPs & fintechs
We work with Canadian businesses that need to demonstrate AML compliance to FINTRAC — whether you are preparing for a scheduled effectiveness review, responding to a FINTRAC examination notice, or strengthening your program proactively.
Our AML audit covers the full scope of your PCMLTFA obligations — from transaction monitoring and KYC file quality to risk assessment validation and STR reporting. At the end of every engagement, you receive a written report suitable for presentation to senior management, satisfying the regulatory requirement for a biennial effectiveness review.
Bill C-12: FINTRAC penalties for serious AML violations now reach $4,000,000 under Bill C-12 (March 2026). Full examinations are active across all sectors. An independent audit is your strongest protection.
What is a FINTRAC AML audit (effectiveness review)?
A FINTRAC Effectiveness Review — also called an independent AML audit — is a structured assessment of your AML compliance program conducted by an external third party. It tests whether your controls work in practice, not just on paper. Under the PCMLTFA regulations, all reporting entities must conduct one at least once every two years, covering:
- AML policies, procedures, and governance structure
- Transaction monitoring systems and suspicious activity reporting
- KYC and Customer Due Diligence (CDD) file quality
- Risk assessment — whether it reflects current business activity
- AML training program — documented, role-specific, and up to date
The findings must be reported in writing to senior management — including all deficiencies, planned corrective actions, and implementation timelines. ComplyFactor delivers a full written report that meets this regulatory requirement.
Who needs an AML audit in Canada?
Any business registered with FINTRAC as a reporting entity is required to have its AML compliance program independently reviewed for effectiveness at least once every two years. This includes:
Money Service Businesses (MSBs)
Currency exchange, remittance, and money transfer businesses.
Payment Service Providers (PSPs / RPAA)
Entities regulated under Canada's evolving payments framework.
Crypto / VASP Companies
Virtual asset service providers registered with FINTRAC.
Finance & Leasing Companies
NEW — April 2026. Finance and leasing firms are now subject to AML compliance obligations.
If your business falls into any of these categories, a biennial AML audit is mandatory.
Common AML audit failures in Canada (MSBs & PSPs)
Based on FINTRAC enforcement actions and our audit work with Canadian businesses, these are the most frequently identified compliance failures:
What our AML audit covers
Our independent AML audit is a full review of your compliance program — tested against FINTRAC's current examination standards. Every engagement covers:
Transaction Monitoring Review
We assess whether your monitoring system is calibrated correctly — including documented thresholds, escalation procedures, and evidence that alerts are being reviewed and actioned.
KYC & Enhanced Due Diligence (EDD) Testing
Risk-based sampling of your customer files — verifying identity verification, source of funds documentation, beneficial ownership records for corporate clients, and ongoing monitoring evidence.
Risk Assessment Validation
We review whether your risk assessment covers the right customer types, geographies, products, and delivery channels — and flag areas that would concern a FINTRAC examiner.
STR & LCTR Compliance Check
We verify that Suspicious Transaction Reports and Large Cash Transaction Reports have been filed correctly, on time, and with the required information.
AML Training Program Review
We confirm that your training is documented, role-specific, completed on schedule, and meets the standard FINTRAC expects during an examination.
Our 4-step AML audit process
Every ComplyFactor AML audit follows the same structured methodology — designed to meet FINTRAC's effectiveness review requirements and deliver a written report your senior management can act on.
Scoping & Population Analysis
We map your full PCMLTFA obligations before any fieldwork begins — identifying your customer cohorts, transaction volumes, geographic exposures, and applicable reporting thresholds. A scoping call confirms scope and timeline.
Control Stress-Testing
We test your controls in practice — recalibrating transaction monitoring thresholds, validating sanctions screening logic, and reviewing your STR escalation process. We apply the same scrutiny a FINTRAC examiner would.
Evidence Sampling
We conduct risk-based sampling of KYC and EDD files — verifying identity verification, source of funds, beneficial ownership, and ongoing monitoring documentation against FINTRAC's current standards.
Remediation Roadmap & Written Report
You receive a full written audit report with all findings, a severity rating per deficiency, and a prioritised action plan with implementation timelines — satisfying the PCMLTFA written reporting requirement.
FINTRAC AML audit requirements in Canada (PCMLTFA & Bill C-12)
Canada's AML enforcement framework was significantly strengthened in 2026. Bill C-12 introduced the largest increase to FINTRAC penalties in the history of the PCMLTFA. FINTRAC's full enforcement phase is now active — the grace period that ran from April 2025 to April 2026 has ended. The cost of an independent AML audit is a fraction of a single FINTRAC penalty.
Book your independent reviewCost of an AML audit in Canada
The cost of an independent AML audit depends on the size of your business, the complexity of your compliance program, and the scope of the review. Key factors include:
- Number of FINTRAC-reportable transaction types your business handles
- Size of your customer base and transaction volumes
- Current state of your AML documentation and controls
- Number of product lines or jurisdictions in scope
ComplyFactor provides transparent, scope-based pricing. We begin with a free 30-minute scoping call and provide a written quote within 48 hours — no retainer required for a standalone audit engagement.
Free quote. Book a free scoping call with our Canada team. Written quote within 48 hours.
+1 807 806 0444
Suite 211, 320 Matheson Blvd West, Mississauga, ON L5R 0H2
How to prepare for a FINTRAC audit
Whether you have received notice of a FINTRAC examination or want to be proactive, these steps will put your business in the strongest position:
Gather compliance documentation
Collect your AML policies, procedures, risk assessment, and training records. FINTRAC expects dated, current versions of all documents.
Review STR and LCTR filing history
Confirm all reports have been filed on time. Late or missing filings are a primary audit finding.
Test KYC files
Review a sample of 10 to 20 customer files. Confirm identity verification, source of funds, and ongoing monitoring documentation is complete.
Check transaction monitoring thresholds
Confirm your system flags the right transactions. Document the thresholds and the logic used.
Commission an independent AML audit
Find and fix gaps on your own terms — before FINTRAC does.
What you get — AML audit deliverables
Every ComplyFactor AML audit engagement includes the following — all within the agreed scope price, with no hidden fees:
Why Canadian businesses choose us for their AML audit
Canada-wide AML specialists
We work with regulated businesses across Canada — MSBs, PSPs, fintechs, and VASPs. Not banks. Not insurance companies. The businesses FINTRAC focuses on.
MSB & PSP focus
Unlike large accounting firms, we focus exclusively on the businesses most frequently targeted in FINTRAC enforcement actions.
Bill C-12 ready
Our audit methodology reflects the March 2026 legislative changes — assessed against the new penalty regime from day one.
Scope-based pricing
No retainer. No surprise fees. We agree scope and price before work begins and provide a written quote within 48 hours.
Remediation support
We do not just identify gaps. We provide a prioritised action plan and can support implementation — so your fixes hold up under the next FINTRAC examination.
Led by Saeed Abbasi, CAMS
Our audits are led by a CAMS-certified specialist with direct MLRO and FINTRAC examination experience across Canadian MSBs and PSPs.
