Fractional MLRO in Canada — a senior AML officer for MSBs, PSPs & fintechs
ComplyFactor provides fractional MLRO services to regulated businesses across Canada — MSBs, PSPs, fintechs, and crypto companies registered with FINTRAC . Our officers bring direct examination experience, current PCMLTFA knowledge, and hands-on familiarity with the reporting obligations that generate the most FINTRAC findings.
Need a named compliance officer for a new FINTRAC registration, interim cover during a staffing gap, or ongoing fractional support without a full-time hire? You get a senior, named officer with fixed-scope pricing and no retainer required.
What is an MLRO — and what does FINTRAC call this role in Canada?
The term MLRO (Money Laundering Reporting Officer) originates in the UK and EU, where it is a legally defined role under domestic AML legislation. In Canada, FINTRAC does not use this term. The equivalent role under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) is the Compliance Officer — the individual named as responsible for the implementation and oversight of a reporting entity's AML compliance program.
The responsibilities are the same. The title is different. Canadian businesses searching for a "fractional MLRO" are looking for exactly the same function — a senior, accountable AML officer who ensures the business meets its PCMLTFA and FINTRAC obligations.
Same role, two names
A senior, accountable officer responsible for implementing and overseeing your AML program. ComplyFactor fills this role on a fractional basis — named in FINTRAC's registry, carrying live obligations.
When Canadian businesses need a fractional MLRO
A fractional MLRO is not a compromise — it is the right structure for most Canadian MSBs and PSPs, which typically lack the transaction volumes to justify a full-time in-house hire. These are the four situations where we are most commonly engaged.
No in-house compliance staff
Most Canadian MSBs don't have the volume to justify a full-time compliance hire — but FINTRAC still requires a named, accountable officer. We become that officer, carrying live responsibility for your program without the cost of an employee.
FINTRAC examination approaching
FINTRAC has made contact or scheduled a review and you need senior compliance leadership now. We step in as your named officer, close priority gaps, and manage the examination response on your behalf.
Compliance officer left or is on leave
A resignation or leave shouldn't strip your FINTRAC registration of a named officer. We provide interim MLRO cover — designated in FINTRAC's records within 24–48 hours — so your obligations never lapse.
New MSB or PSP registration
A new FINTRAC registration requires a named compliance officer from day one. We take that role, build the program behind it, and ensure the appointment stands up to examination — not just the registration form.
What our fractional MLRO does for your Canadian business
Not a consultant who reviews your program once a year. Our named officers carry active, ongoing responsibility for your AML function — the same obligations a full-time in-house hire would carry, delivered on a fractional basis.
PSPs, note: Payment Service Providers regulated under the Retail Payment Activities Act (RPAA) carry dual obligations — FINTRAC compliance and Bank of Canada oversight. Our fractional MLRO service covers both.
What our fractional MLRO engagement covers
Not every business needs the same scope. This maps each core obligation to the engagement type it falls under — so you know exactly what's included before signing anything.
Our fractional MLRO process
Every engagement follows a consistent four-step approach — scoped before it starts, delivered by a named senior officer, and structured for FINTRAC's examination requirements.
Scoping call — free, 30 minutes
We assess your business type, FINTRAC registration status, current compliance setup, and what you actually need from a fractional MLRO. No assumptions, no upselling.
Engagement letter — 48 hours
Fixed scope, fixed monthly fee, named officer, and start date — confirmed in writing before any work begins. No retainer for standalone program-build engagements.
Designation & program review
Your named MLRO is confirmed in FINTRAC's records. We review your existing program, identify priority gaps, and begin active management within the first week.
Ongoing compliance management
Monthly reporting oversight, STR and EFTR management, risk assessment maintenance, training delivery, and FINTRAC correspondence — for the term of the engagement.
FINTRAC's compliance officer requirements under the PCMLTFA
Under Section 9.6 of the PCMLTFA , every reporting entity must appoint a senior officer responsible for implementing and overseeing the AML compliance program.
FINTRAC examines this appointment directly — the individual must be named in your FINTRAC registration , must have sufficient authority within your organisation, and must be demonstrably engaged in the program, not merely listed on a form.
A ComplyFactor fractional MLRO satisfies s.9.6 in full — named, authoritative, and actively engaged from the first week of the engagement.
What Canadian businesses receive
Every engagement includes written documentation — not verbal-only guidance. Here is what your business receives, by engagement type.
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Fractional MLRO vs full-time hire
Most Canadian MSBs and PSPs do not need a full-time compliance officer. A senior AML officer commands $120,000–$160,000 a year, plus benefits, payroll, and the management overhead of a specialist employee. For a business processing $5M–$50M annually, that structure makes no sense.
Why Canadian MSBs & PSPs choose ComplyFactor
Active, named officers — accountable for live obligations in the context FINTRAC actually examines.
A named senior officer — by name
Your engagement is led by a CAMS-certified senior AML officer with direct FINTRAC examination experience — named in your engagement letter and in FINTRAC's records.
MSB & PSP focus exclusively
We do not serve banks or insurers. Every hour of MLRO work we deliver is in the context FINTRAC actually examines — MSBs, PSPs, fintechs, and VASPs.
Active, named officers — not advisors
Our fractional MLROs are compliance officers of record — named in FINTRAC's systems, accountable for live obligations. Not consultants who review documents once a year.
RPAA dual compliance covered
PSPs carry both FINTRAC and Bank of Canada obligations. Our officers cover both — most MLRO providers cover only one.
Immediate start for urgent situations
Staffing gap or examination notice? Named MLRO designation and FINTRAC records updated within 24 to 48 hours.
Frequently asked questions — fractional MLRO Canada
A fractional MLRO is a senior AML compliance officer who acts as your named Compliance Officer under the PCMLTFA on a part-time or shared basis — taking on all the same responsibilities a full-time in-house officer would carry, at a fraction of the cost. In Canada, FINTRAC refers to this role as the Compliance Officer, but the function is identical to what UK and international businesses know as the MLRO. Our fractional MLROs are named in FINTRAC's records and actively manage your reporting obligations, risk assessment, training, and program documentation.
Yes. The PCMLTFA requires a named senior officer responsible for your AML compliance program — it does not require that officer to be a full-time employee. Your fractional MLRO is designated as your Compliance Officer in FINTRAC's registry. From FINTRAC's perspective, this is indistinguishable from an in-house hire. The individual must, however, have genuine authority within your organisation and be actively engaged in the program — not simply listed in name only.
For urgent situations — staffing gaps or examination notices — a named MLRO can be in place and FINTRAC records updated within 24 to 48 hours. For planned engagements, we deliver a written proposal within 48 hours of a free scoping call and begin active management within the first week of engagement.
Yes — FINTRAC reporting is a core responsibility of every ComplyFactor fractional MLRO engagement. This includes Suspicious Transaction Reports (STRs), Electronic Funds Transfer Reports (EFTRs), Large Cash Transaction Reports (LCTRs), and Large Virtual Currency Transaction Reports (LVCTRs). All reports are filed within FINTRAC's mandatory timelines with supporting documentation maintained in your compliance records.
We price all MLRO engagements on a fixed monthly fee — not hourly billing. The fee depends on your business size, transaction volumes, and the scope of obligations to be managed. A straightforward MSB with low transaction volumes requires less MLRO time than a multi-product PSP with complex reporting. We provide a written fee proposal within 48 hours of a free scoping call. Contact us at +1 807 806 0444.
PSPs regulated under the Retail Payment Activities Act (RPAA) carry dual regulatory obligations — FINTRAC compliance under the PCMLTFA and operational oversight from the Bank of Canada. Most fractional MLRO providers are trained only in FINTRAC obligations. ComplyFactor's officers are trained in both, which means PSPs receive MLRO support that covers the full scope of their regulatory exposure rather than just one part of it.
Book a free Canada AML consultation
Tell us about your business and we'll confirm which services you need — free, no obligation, 30 minutes.
