How to Prepare for a FINTRAC Examination: A Comprehensive Guide for Reporting Entities

Understanding the FINTRAC Examination Process

Before diving into the preparation steps, it’s essential to understand the examination process:

1. Notification: FINTRAC typically provides notice before conducting an examination. This notification includes the scope and purpose of the examination. This notification process involves a call followed by written communication, which outlines the details of the examination, its scope, and the expected timeline.
2. Documentation Request: You will be asked to provide various documents, records, and information related to your AML/ATF practices.
3. On-Site Visit: In some cases, FINTRAC examiners may visit your business premises to conduct interviews and review records. In other cases, it could be a virtual or desk examination.
4. Assessment: FINTRAC examines your AML/ATF program, know-your-customer (KYC) practices, reporting procedures, and record-keeping to ensure compliance.
5. Feedback: Following the examination, you will receive feedback, recommendations, or requirements from FINTRAC (through a formal letter) to enhance your compliance program.

Preparing for a FINTRAC Examination

1. Know Your Obligations: Familiarize yourself with your legal obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations. Ensure your AML/ATF program is in line with these requirements.
2. Organize Documentation: Collect and organize all relevant documentation, including AML/ATF policies, procedures, training records, risk assessments, and customer files.
3. Review and Update Policies & Procedures: Thoroughly review your AML/ATF policies and procedures. Ensure they are up to date, approved by senior management and reflect current regulations and industry best practices.
4. Know-Your-Customer (KYC): Review your KYC procedures. Make sure you have documented processes for verifying customer identities and assessing risk.
5. Reporting: Ensure you have processes in place to report reportable transactions like large cash transactions (LCTs) and electronic funds transfers (EFTs) to FINTRAC.
6. Record Keeping: Establish efficient record-keeping systems to retain customer information, transaction records, and the various transaction reports (such as STRs and EFTRs) submitted to FINTRAC.
7. Training: Ensure that your staff are adequately trained in AML/ATF compliance and that records of training are maintained.
8. AML Review and Self-Assessment: Ensure your AML Review is completed within the required period. Also, ensure you conduct a self-assessment to identify and rectify potential compliance gaps before FINTRAC does.
9. Cooperation and Transparency: Be prepared to cooperate fully with FINTRAC examination officers, providing requested documents and facilitating interviews.
10. Consult with Experts: Consider seeking assistance from compliance experts who specialize in AML/ATF regulations to ensure your readiness for the examination.

How We Can Help MSBs

At C&G Professional Services Inc., we specialize in assisting reporting entities such as MSBs, real estate firms, financial entities, and FINTECHs in preparing for FINTRAC examinations. Don’t wait until FINTRAC examination notice arrives; be proactive in securing your entities’ compliance and reputation.

To learn more about how we can assist your business in preparing for a FINTRAC examination, please contact us at:

• Email: info@candg.ca
• Website: www.candg.ca

Phone: +1 (289) 505-1158