AML Compliance Services for Portfolio Managers
Managing money on a discretionary basis means that you alone decide where client funds actually go, which places the obligation to understand where those funds originally came from squarely with you instead.
- FINTRAC Registered
- Cross-Border Expertise
- Audit Ready
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Discretionary Authority and Source of Wealth
Portfolio managers hold discretionary authority, which changes the compliance relationship considerably. A client who instructs each trade is making their own decisions, while a client who hands over discretion is asking you to act. That authority carries responsibility for understanding whose money you are managing and where it genuinely originated before it ever arrives in the account.
Source of wealth matters more here than transaction monitoring does. A discretionary mandate produces trading you initiated rather than activity a client generated, so the unusual patterns a dealer looks for simply do not appear. What appears instead is the funding itself, arriving from a client whose financial position either explains the amount or does not. Establishing that at onboarding is where the real work sits.
Compliance Support for Portfolio Managers
We deliver securities dealer programme development, source of wealth verification procedures, client onboarding frameworks, funding source controls, beneficial ownership identification, independent effectiveness reviews, and ongoing compliance officer support for discretionary portfolio management firms.
PSP Registration
End-to-end PSP registration support under Canada's Retail Payment Activities Act framework.
MSB Licensing
Complete MSB licensing and FINTRAC registration for money services businesses nationwide.
Banking
Deliver secure banking compliance solutions supporting regulatory excellence and operational efficiency.
AML Compliance
Build robust AML frameworks ensuring regulatory compliance and effective financial crime prevention.
Regulatory Consulting
Receive strategic regulatory advice supporting sustainable growth and complete compliance confidence.
Transaction Monitoring
Ongoing transaction monitoring and screening to detect and report suspicious activity.
Why Portfolio Managers Choose Us
We focus our diligence precisely where discretionary management actually creates exposure, which is the funding arriving into the account rather than the trading that you subsequently decide to carry out.
Source Of Wealth
We establish where client money genuinely originated, since discretionary managers cannot rely on trading patterns to reveal anything.
Onboarding Done Properly
We build client onboarding that establishes financial position, because discretion means the real diligence happens before any money arrives.
Funding Sources Checked
We build controls around where subscriptions and top ups come from, including funds arriving from unexpected third parties.
Full Programme Covered
We cover every pillar the securities dealer obligation requires, including the biennial independent review firms regularly forget about.
Portfolio Managers We Support
We support portfolio management firms in every province right across the whole of Canada today, from the smallest independent managers through to divisions operating inside much larger financial institutions nationally.
What Our Clients Say
Canadian financial firms trust ABM Global Compliance to navigate complex regulation with clarity and care. From MSB licensing to ongoing AML support, our clients value our responsiveness, expertise, and genuine commitment to their long-term compliance success.
Let's Talk About Your Compliance Needs
Schedule a Free Consultation
Whether you’re starting a new MSB or need ongoing AML support, our team responds within one business day.
Portfolio Manager Questions
Clear and direct answers to the questions portfolio managers ask most about their obligations under Canadian anti money laundering law.
Are portfolio managers reporting entities?
Yes. Portfolio managers fall within the securities dealer category and carry the full compliance programme obligation under Canadian law.
Why does source of wealth matter?
Because discretionary trading is yours rather than the client’s, so funding arriving into the account is where genuine risk appears.
Does trade monitoring help us?
Less than it helps dealers. You initiated the trading, so unusual client driven patterns simply never appear in your accounts.
Money arrived from somebody else
Third party funding needs explaining and recording properly. It may be entirely innocent, but it should never pass unexamined.
How often is review required?
Canada requires an independent effectiveness review every two years, carried out by somebody genuinely independent of the operations being reviewed.