FINTRAC Examination Assistance

A FINTRAC examination is the most consequential regulatory event most reporting entities will face. The outcome is decided by what you did in the weeks before it, not on the day.

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🏛 Examination Support Prepare Now

FINTRAC examinations follow a predictable structure: a notice, a document request, a review of your compliance program against the requirements, testing of your records and reporting, interviews, and a findings letter. What varies is how prepared the reporting entity is when the notice arrives.

C&G prepares entities for examination and supports them through it. That means a mock assessment against the criteria examiners actually apply, rapid remediation of what the mock surfaces, an organised examination binder, coached staff, and someone in the room who has been through this before.

We have guided credit unions, MSBs, virtual currency dealers, and payment businesses across Canada through FINTRAC examinations, and we have written the reviews examiners read. Having worked both sides, we know which deficiencies escalate, which ones are explained away with the right documentation, and how to present a program in its strongest defensible form.

What the engagement includes

  • Pre-examination mock assessment against current FINTRAC examination criteria
  • Gap analysis with findings prioritised by likely regulatory consequence
  • Rapid remediation support on the gaps that matter before the examination date
  • Document organisation and examination binder preparation
  • Response drafting for the FINTRAC document request
  • Staff coaching and examiner interview preparation
  • On-site or virtual support during the examination itself
  • Post-examination findings review and response drafting
  • Remediation planning, implementation, and progress tracking against undertakings
How it works

How the engagement runs

STEP 01

Readiness assessment

We run the examination before FINTRAC does, using the same criteria, and give you an honest picture of what would be found today.

STEP 02

Prioritised remediation

Not everything can be fixed before the date. We rank the gaps by likely consequence and close the ones that drive findings and penalties first.

STEP 03

Examination preparation

The document request is answered completely and consistently, the binder is organised the way examiners work through it, and staff are coached on the interviews.

STEP 04

Examination support

We are available throughout the examination to manage information requests, sit in on interviews where appropriate, and keep responses consistent.

STEP 05

Findings response and remediation

We draft the response to the findings letter, negotiate realistic remediation timelines, and manage the remediation through to closure.

Who this is for

Businesses we deliver this for

FAQ

FINTRAC Examination Assistance: common questions

The five required elements of the compliance program, and testing against them: whether the compliance officer is appointed with real authority, whether policies and procedures are current and followed, whether the risk assessment is documented and defensible, whether training happened and was recorded, whether the two-year effectiveness review was completed, and whether reporting and record-keeping obligations were met on the sample tested.
Yes. Post-examination work is a substantial part of what we do. We review the findings, draft the response, and design a remediation program that satisfies FINTRAC while genuinely fixing the underlying causes. Responding well matters, because the response shapes what happens next.
AMPs follow from the nature and severity of the violations found, whether harm was done to FINTRAC objectives, the entity compliance history, and whether the entity took reasonable steps. The pattern is consistent: penalties escalate where deficiencies were known and not addressed, and where reporting obligations were missed.
It is the single highest-value preparation available. A mock assessment tells you what would be found today, at a point when you still have time to fix it. Entities that do this routinely rarely receive serious findings, because nothing in the examination is a surprise.
Yes, on-site or virtually. We manage information requests, keep responses consistent across the team, and make sure staff are not answering questions they should not be answering alone.
Three things, in order. Read the document request carefully and diarise the deadline. Do not start sending documents piecemeal. Then get an honest internal picture of what those documents will show, because the response you give is easier to manage when you already know where the weak points are. Bringing in help at the notice stage is far more effective than after the findings letter, when the options narrow considerably.
It varies with the size of the entity and the state of the documentation, but plan for the process to run over weeks rather than days, followed by a further period before findings are issued. The elapsed time is largely driven by the back-and-forth on information requests. Entities that respond completely and consistently the first time shorten it considerably.
An AMP is a monetary penalty FINTRAC can impose for non-compliance with the PCMLTFA. Violations are classified by seriousness, and the penalty reflects factors including the harm done to the Act’s objectives, the entity’s compliance history, and whether it acted in good faith. Bill C-12 came into force on 26 March 2026, raising maximum penalty amounts substantially, introducing compliance orders and mandatory compliance agreements, and allowing FINTRAC to consider ability to pay. Violations before that date remain under the previous framework. See what changed on 26 March 2026.
FINTRAC publishes information about administrative monetary penalties it imposes. For most reporting entities the reputational and banking consequences of appearing on that list outweigh the penalty amount itself, particularly for MSBs and payment businesses whose access to banking depends on their compliance standing. That is a large part of why early remediation is worth the investment.
There is a process for making representations before a penalty is imposed and avenues to seek review of a decision afterwards. Both are time-limited and both are considerably stronger when supported by evidence that the deficiency was addressed. In our experience the representations stage is under-used: entities accept findings they had good grounds to contest, or contest findings without the documentation to support the argument.
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Examination notice received?

Send us the notice and the document request. We will tell you where you stand and what to close first.

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