Independent Effectiveness Review of Your Compliance Program
Every two years your compliance program must be reviewed by someone independent of it. We deliver that review, test each pillar against how FINTRAC examines it, and give you a documented action plan.
The Two-Year Review Every Program Requires
The law requires your compliance program to be reviewed at least every two years. The reviewer must be independent of the program they assess, which is why your own compliance officer cannot credibly review their own work. We provide the independence and the rigour the requirement demands.
A Real Test, Not a Document Read
An effectiveness review does far more than confirm the paperwork exists. We test whether your program actually works in practice, sampling transactions and records, interviewing your staff, and checking that policies are genuinely followed on the ground. We assess every pillar, then document our findings and a remediation plan your senior management can act on.
Program Testing
We test each pillar of your compliance program against how it performs in practice.
Sample Review
We sample transactions, records, and reports to check your controls actually operate.
Findings Report
We document clear findings and rate the significance of every gap we identify.
Remediation Plan
We give you a prioritised action plan to close each gap before examination.
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Programs We Regularly Review
We review compliance programs for money services businesses, payment service providers, cryptocurrency platforms, currency exchanges, real estate firms, and other reporting entities that owe a two-year review under the PCMLTFA.
We support banks with program design, oversight, & regulatory examination readiness.
We help credit unions meet obligations proportionate to their membership and scale.
We handle registration, renewals, reporting, & controls FINTRAC expects from you.
We cover Bank of Canada registration alongside your anti money laundering obligations.
We establish what your wallet activity triggers, then build only what applies.
We build compliance around what your product does, before volumes and questions arrive.
We register virtual currency dealers and build the reporting their activity demands.
We support financial institutions across registration, program build, and reporting duties.
Why Businesses Choose Our Reviews
Genuinely Independent
We sit outside your compliance function entirely, so your review carries the independence FINTRAC and your board both expect.
Examiner Perspective
We test your program the way an examiner would, so weaknesses surface with us rather than during an inspection.
Actionable Output
You receive clear findings and a prioritised plan, not a vague report that leaves you unsure what to fix.
Reviewing Programs Across Canada
We deliver independent effectiveness reviews right across Canada, from Toronto and Montreal through to Vancouver and Calgary, and for foreign reporting entities that carry Canadian obligations wherever they are based.
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.
Effectiveness Review Questions
Clear answers to the questions Canadian businesses ask most about the mandatory two-year independent review of their AML compliance program.
How often is the review required?
At least every two years. The PCMLTFA requires your compliance program to be reviewed on that cycle, and sooner if your business changes materially.
Who can perform the review?
Anyone independent of the program, whether an external firm or an internal person not responsible for it. Most businesses choose an external reviewer.
What does the review examine?
Your policies and procedures, risk assessment, training, and ongoing compliance, tested through sampling and interviews, not just a review of documents.
What do we receive at the end?
A documented report of findings, the significance of each, and a remediation plan, which you report to a senior officer or board.
Does FINTRAC ask for the review?
Yes. FINTRAC commonly requests the review and evidence you acted on its findings, and a missing review is a frequent examination finding.