AML Compliance Program Development

The full compliance documentation suite the PCMLTFA requires, built around how your business actually operates rather than dropped in from a template.

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๐Ÿ“ Program Development Build Your Program

Every regulated business in Canada must have a documented AML/ATF compliance program. The Act sets out five required elements: an appointed compliance officer, written policies and procedures, an enterprise-wide risk assessment, an ongoing training program, and the two-year effectiveness review. Missing or generic documentation on any one of them is a finding waiting to happen.

C&G designs and writes programs that are regulatory-grade and practical to operate. That distinction matters. A policy manual no one in the business can follow produces exactly the gap between documented and actual practice that examiners look for. We write to the way your onboarding, payments, and escalation actually work.

Whether you are a first-time registrant building from nothing or an established entity replacing a framework that has drifted out of date, the deliverable is a complete, defensible documentation set built for your business, not a template with your logo dropped into the header.

What the engagement includes

  • Enterprise-wide AML/ATF risk assessment covering products, clients, geographies, channels, and technology
  • AML compliance policies and procedures manual
  • KYC and customer due diligence procedures, including enhanced due diligence triggers
  • Beneficial ownership and third-party determination policy
  • Politically exposed person and head of international organisation procedures
  • Transaction monitoring policy with business-specific red-flag indicators
  • STR escalation, decision-making, and reporting procedures
  • Record-keeping and retention schedule
  • AML/ATF training curriculum and materials
  • Compliance officer (CAMLO) mandate and accountability framework
How it works

How the engagement runs

STEP 01

Business and risk discovery

We map your products, delivery channels, customer segments, geographies, and third-party relationships. The risk assessment is built from this, not retrofitted to it.

STEP 02

Enterprise-wide risk assessment

A documented, defensible methodology producing inherent risk ratings, control effectiveness ratings, and residual risk by category, with the reasoning shown.

STEP 03

Policy and procedure drafting

The full documentation suite, drafted to your operating model and to current FINTRAC guidance, with clear ownership at every control point.

STEP 04

Review and calibration

We walk the draft through with your compliance officer and operational leads to confirm every procedure is one your team can actually execute.

STEP 05

Handover and training

Final documentation, a training curriculum keyed to the program, and a board-ready summary of what has been put in place and why.

Who this is for

Businesses we deliver this for

FAQ

Compliance Program Development: common questions

An appointed compliance officer with the authority and resources to do the job; written compliance policies and procedures kept current and approved by a senior officer; an enterprise-wide risk assessment; an ongoing written training program for employees, agents, and mandataries; and an independent effectiveness review at least every two years.
You can, and FINTRAC will notice. A template describes a generic business. Examiners test whether your documented controls match what your staff actually do, and generic documentation almost always fails that test. Templates are also a poor foundation for the risk assessment, which by definition has to be specific to your business.
For a single-product MSB, typically three to five weeks. For a multi-product entity, a PSP with an RPAA framework running in parallel, or a group with several registrations, six to ten weeks is more realistic. Discovery is the rate-limiting step, and it moves faster when your operational leads are available.
Yes. The obligation to have a compliance program attaches from the moment you begin conducting triggering activities, and registration is not a grace period. In practice we build the program alongside the registration application so both land together.
Both, as separate engagements. Development produces the documentation. Implementation embeds it into your systems, workflows, and staff behaviour. Many clients take them together; the two are scoped and priced separately so you can decide.
Yes. The Act requires an appointed compliance officer, often called the CAMLO, with real authority and adequate resources, but it does not require that person to be a full-time employee. C&G provides outsourced and fractional compliance officer services for businesses that are not yet at the scale to justify a full-time hire. Ask us about a fractional CAMLO arrangement when we scope the program.
The risk assessment and the policies must be kept current, which means reviewing them whenever your business changes materially, whenever the regulations change, and on a documented periodic cycle regardless. Most entities set an annual review with an out-of-cycle trigger for new products, channels, or geographies.
CAMLO stands for Chief Anti-Money Laundering Officer. It is industry shorthand rather than a statutory term: the PCMLTFA simply requires a reporting entity to appoint a compliance officer responsible for the compliance program. In Canadian practice the two terms are used interchangeably, and "CAMLO" is what you will see in job titles, banking questionnaires, and partner due diligence requests.
Yes. The Act requires that a compliance officer be appointed with the authority and resources to carry out the role. It does not require that person to be a full-time employee. What matters is that the appointment is real: documented authority, direct access to senior management, sufficient time allocated, and genuine involvement in decisions. An outsourced officer who exists only on paper fails the same test an internal one would.
Owns the compliance program day to day: keeps policies and the risk assessment current, oversees KYC and monitoring escalations, makes and documents STR decisions, manages FINTRAC reporting and registration obligations, delivers or arranges training, reports to senior management and the board, and fronts examinations and independent reviews. It is the compliance officer role, sized to a business that does not yet need it full time.
Newly registered MSBs and PSPs that need a credible compliance officer before they can justify a full-time hire; businesses whose compliance officer has resigned, leaving the role vacant and the obligation live; fintechs whose banking partner has made a named, qualified compliance officer a condition; and smaller reporting entities where the role currently sits with a founder or finance lead who has no AML background.
Yes, entirely. Outsourcing the role does not outsource the obligation. The reporting entity remains responsible for compliance with the Act, and senior management remains accountable for the program. What an external officer brings is expertise, capacity, and independence from the commercial side of the business. What it does not do is transfer liability, and any provider suggesting otherwise should be treated with caution.
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Building a compliance program from scratch?

Tell us what you do and where. We will scope the documentation set your registration actually requires.