How to Prepare for a FINTRAC Examination as an MSB

As a Money Services Business (MSB) operating in Canada, compliance with Anti-Money Laundering (AML) regulations is not optional — it is a legal obligation under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). FINTRAC, the Financial Transactions and Reports Analysis Centre of Canada, is the regulatory body responsible for monitoring compliance, and from time to time it will conduct an examination of your business.

Such an examination can feel daunting, particularly for smaller MSBs or those without dedicated compliance staff. But with proper preparation, the process can be a smooth and straightforward one. Below are the key steps every MSB should take before a FINTRAC examiner arrives.

1. Review and Update Your AML Policies and Procedures

The first and most fundamental step is to ensure your AML policies and procedures are current, accurate, and aligned with FINTRAC’s requirements. Regulations evolve, and documentation that was compliant two years ago may not reflect current obligations today. Review your policies against the latest FINTRAC guidance, update any outdated provisions, and confirm that your procedures are being consistently followed in practice — not just written down.

Regular internal audits are also strongly recommended. These help identify weaknesses in your compliance program before an examiner does.

2. Implement Robust Customer Due Diligence (CDD) Measures

MSBs are required to conduct customer due diligence (CDD) measures, including verifying the identity of clients and assessing the risk of money laundering or terrorist financing associated with their transactions. FINTRAC examiners will scrutinise your CDD processes closely — reviewing how you collect client information, how you assess risk, and whether your Know Your Customer (KYC) records are complete and up to date.

Ensure your CDD processes are documented, consistently applied, and supported by adequate records for every client relationship and transaction.

3. Train Your Employees

Employee training is a critical pillar of any AML compliance program. Your staff must understand the importance of AML compliance, the requirements of the PCMLTFA, and your institution’s specific policies and procedures. FINTRAC examiners will ask about your training program — including how often training is delivered, what it covers, and how you document it.

Establish a regular training schedule, keep records of who has been trained and when, and ensure that new employees receive AML training before they begin handling transactions.

4. Maintain Accurate and Accessible Records

MSBs are required to maintain detailed records of their transactions and client information, including records of customer identification, transaction monitoring activity, and suspicious transaction reporting. These records must be kept for a minimum of five years and must be made available to FINTRAC upon request.

Before an examination, confirm that your record-keeping system is organised, complete, and that designated staff know how to retrieve records quickly. Disorganised or incomplete records are one of the most common sources of examination findings.

5. Conduct a Self-Assessment Before the Examination

A self-assessment is one of the most valuable tools available to an MSB preparing for a FINTRAC examination. It involves reviewing your own compliance program against FINTRAC’s assessment criteria — identifying gaps and addressing them before the examiner does. This proactive approach demonstrates your commitment to compliance and reduces the likelihood of adverse findings.

If you are unsure how to conduct a meaningful self-assessment, consider engaging an independent compliance consultant to perform a pre-examination review on your behalf.

6. Be Transparent and Cooperative During the Examination

FINTRAC examinations can be lengthy, and examiners may request substantial documentation and information. It is essential to be transparent and cooperative throughout the process. Attempting to obstruct or delay an examination — or providing incomplete information — will reflect poorly on your organisation and may result in more serious consequences.

Assign a dedicated point of contact to liaise with the examiner, prepare a list of documentation you expect to be requested, and respond to information requests promptly and completely.

7. Seek Expert Assistance

If you are unsure about any aspect of your AML compliance program, or if you have received notice of an upcoming examination, seek professional assistance promptly. An experienced AML compliance consultant can review your program, identify gaps, assist with documentation, and coach your team on what to expect.

C&G Professional Services has worked with MSBs, credit unions, crypto exchanges, and other reporting entities across Canada to prepare for FINTRAC examinations. Our team conducts comprehensive pre-examination reviews of AML policies and procedures, provides targeted employee training, and assists with record-keeping and documentation to ensure clients are fully prepared before the examiner arrives.