Fractional compliance officer Canada
FINTRAC reporting entities must appoint a compliance officer who is responsible for implementing the compliance program. ComplyFactor provides outsourced compliance officer support for Canadian MSBs and FMSBs that need ongoing FINTRAC oversight, program management, reporting support, and regulatory readiness without building a full in-house compliance function.
ComplyFactor works with new MSBs and FMSBs registering with FINTRAC, businesses replacing a departing compliance officer, programs that need strengthening, and businesses preparing for FINTRAC review. Each engagement has a defined compliance officer scope, written deliverables and ongoing support.
What does a compliance officer do under the PCMLTFA?
FINTRAC reporting entities must appoint a compliance officer who is responsible for implementing the compliance program. The officer must have the authority and access to resources needed to carry out the role, understand the business and its AML risks, and have sufficient knowledge of the PCMLTFA and associated Regulations. Appointment on paper does not meet the requirement. Specific duties may be delegated to other employees, but the compliance officer remains responsible for effective implementation and oversight of the program.
In practice, the compliance officer is responsible for five core obligations under the PCMLTFA, and FINTRAC examines each of them directly:
Written policies & procedures
Whether your written compliance policies and procedures are current, specific to your business, approved where required, and kept up to date as regulatory or operational changes occur.
Risk-based approach
Whether your documented risk assessment reflects your clients and business relationships, products and services, delivery channels, geographic exposure, new technologies, and other relevant risk factors.
Ongoing training
Whether a written, ongoing compliance training program and training plan are maintained, with appropriate training delivered and documented for relevant employees, agents, mandataries, and other authorized persons.
Two-year effectiveness review
Whether the compliance program has undergone the required effectiveness review at least every two years, including testing of the policies and procedures, risk assessment, and ongoing training program and plan.
Reporting obligations
Whether applicable FINTRAC reporting obligations, including STRs, LCTRs, EFTRs and LVCTRs where required, are identified, filed within the applicable timelines, and supported by appropriate records.
When Canadian businesses need a fractional compliance officer
PCMLTFA compliance is an ongoing obligation. These are the four situations where Canadian MSBs and PSPs most commonly engage ComplyFactor.
No designated compliance officer in place
If an MSB or FMSB does not have an appropriate compliance officer in place, ComplyFactor can provide outsourced compliance officer support and help document the appointment, responsibilities, authority, and any required FINTRAC registration updates.
FINTRAC examination notice received
If your business receives a FINTRAC examination notice or other regulatory contact, ComplyFactor can provide senior compliance support, organize requested evidence, identify priority gaps, coordinate remediation, and help your team prepare for the examination process.
Compliance officer role is vacant or transitioning
If your compliance officer resigns, goes on leave, or the role is transitioning, ComplyFactor can provide interim compliance officer support, maintain priority AML oversight, document the transition, and assist with any required FINTRAC registration updates.
Program exists but has not been maintained
If your compliance program has not kept pace with changes in your business or regulatory requirements, ComplyFactor can review the existing framework, update the risk assessment and policies, identify control gaps, and prioritize remediation.
What a fractional compliance officer does for your business
Our outsourced compliance officer service provides ongoing AML oversight and support across the compliance activities included in the engagement. Typical day-to-day responsibilities can include:
What our fractional compliance officer engagement covers
The scope matrix below maps each core compliance obligation to the engagement types that include it, so you know what is included before you sign.
Our process: from scoping call to named officer
Every engagement follows the same four steps. The scope is agreed before work starts, and a named senior officer delivers the work.
Scoping call: free, 30 minutes
We review your business model, FINTRAC registration status where applicable, current compliance setup, and immediate priorities. The call helps define whether you need ongoing compliance officer support, interim cover, examination support, or a standalone compliance project.
Written scope & engagement letter
You receive a written engagement letter setting out the scope, responsibilities, fee structure, proposed start date, and designated contacts before ongoing work begins.
CO designation & program review
Where a Compliance Officer appointment or MSB/FMSB registration update is required, we help document and support that process. We then review the existing compliance program, identify priority gaps, and begin the agreed ongoing support.
Active compliance management
Ongoing support can include FINTRAC reporting oversight, risk assessment maintenance, training, transaction monitoring, recordkeeping, regulatory correspondence, and documented activity reporting, based on the agreed scope.
FINTRAC Compliance Officer Requirements in Canada
FINTRAC reporting entities must appoint a compliance officer who is responsible for implementing the compliance program. The officer needs sufficient authority and access to resources, knowledge of the business and its risks, and an understanding of the applicable PCMLTFA and regulatory requirements. FINTRAC examinations assess whether the compliance program has been adequately implemented and maintained in practice.
What FINTRAC assesses
Bill C-12 strengthened FINTRAC's administrative monetary penalty framework in March 2026, including higher maximum penalties for prescribed serious violations. This increases the importance of documented compliance oversight, timely remediation, and clear accountability within the compliance program.
What Canadian businesses receive
Every engagement produces documented outputs within the agreed scope. They help your team manage compliance activities, support governance, and keep evidence for regulatory review.
Fractional vs full-time
A fractional compliance officer can be a practical option for MSBs and FMSBs that need ongoing senior AML oversight without building a full-time in-house compliance function. The right model depends on the business’s size, transaction volumes, regulatory complexity, internal resources, and level of day-to-day compliance support required.
Why Canadian MSBs & PSPs choose ComplyFactor
Ongoing AML compliance support covering program implementation, FINTRAC readiness, and day-to-day oversight.
A named senior officer
Your engagement is led by a named senior compliance specialist who is identified in the engagement documentation and provides ongoing oversight of the agreed compliance scope. Where an MSB or FMSB registration update is required, ComplyFactor can support that process.
PCMLTFA specialists
Our Canadian AML work focuses on MSBs, FMSBs, fintechs, payment businesses, and virtual currency businesses with applicable FINTRAC obligations.
Ongoing compliance oversight
Our outsourced compliance officer service provides ongoing program oversight and support across the responsibilities included in the engagement.
Written deliverables on every engagement
Every engagement closes with documented output: policies, risk assessments, training records, and monthly logs.
Fixed-scope pricing: written before work begins
The monthly fee is agreed in writing before the engagement starts. The engagement has no open-ended retainer and no hourly billing.
Frequently asked questions: fractional compliance officer Canada
A fractional compliance officer provides ongoing AML compliance oversight on a part-time or outsourced basis. For FINTRAC purposes, the main requirement is that an appropriate Compliance Officer is formally appointed and has the authority, knowledge, and access to resources needed to implement the compliance program. The scope can include program oversight, reporting support, risk assessment maintenance, training, monitoring, and regulatory correspondence.
FINTRAC requires a person to be appointed as the Compliance Officer responsible for implementing the compliance program. Its guidance does not require that person to hold a specific “fractional” title. The appointed officer must have sufficient authority, knowledge, resources, and genuine involvement in the program. The reporting entity remains ultimately responsible for meeting its PCMLTFA obligations.
An AML consultant typically provides project-based advice, such as building policies, conducting a gap analysis, or supporting remediation. An outsourced Compliance Officer provides ongoing oversight of the compliance program and the responsibilities included in the engagement. In Canada, businesses may also use the term MLRO for a similar senior AML leadership function, although FINTRAC formally uses the term Compliance Officer.
A compliance officer transition should be documented carefully so responsibilities, records, reporting history, open remediation items, and upcoming deadlines are clearly handed over. ComplyFactor can prepare a structured transition package and support any required MSB or FMSB registration updates once the new appointment is confirmed.
ComplyFactor uses scope-based monthly pricing for outsourced compliance officer engagements. Fees depend on the business model, transaction volumes, regulatory complexity, reporting requirements, and level of ongoing support required. A lower-complexity MSB may require a lighter scope than a multi-product payment business with extensive monitoring and reporting needs. We provide a written fee proposal after the scoping call.
Yes. A fractional compliance officer can support FINTRAC examination preparation by organizing requested records, reviewing the current compliance program, identifying priority gaps, coordinating remediation, preparing explanations, and helping management respond to regulatory requests. Examination support can also be included within an ongoing compliance officer engagement.
Book a Free MSB Compliance Officer Consultation
Tell us about your business, current compliance setup, and the level of Compliance Officer support you need. We’ll scope the engagement and explain the appropriate next steps in a free 30-minute consultation.
