Common AML program failures for Canadian MSBs
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental — and most are preventable.
MSB registration timing and sequencing
A practical primer on timing, sequencing, and common registration planning issues for Canadian MSB registration.
MSB registration timing depends on the business model, readiness of compliance materials, ownership information, product launch sequencing, and whether banking or processor partners require evidence of regulatory planning.
Practical sequence
Teams usually need to understand the activity first: fund flows, customer roles, custody, foreign exchange, remittance features, virtual currency activity, and the role of each partner in the payment chain.
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View All Posts »Documentation matters more than policy language
In a FINTRAC examination, the records that show how the compliance program runs carry more weight than the policies that describe it.
Financial technology regulation in Canada
Canadian fintech regulation turns on what a product does, not what it is called — and the analysis starts with the flow of funds.
Preparing for a FINTRAC examination
FINTRAC examinations test operating evidence, not just policy documents — preparation means assembling the records that show how the compliance program runs in practice.