· FINTRAC
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.
Tag: FINTRAC
- · Crypto
Crypto exchange MSB obligations in Canada
Canadian crypto exchanges are required to register as MSBs with FINTRAC and maintain a full AML compliance program — the obligations are specific and the enforcement record is growing.
- · FINTRAC
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.
- · FINTRAC
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.
- · FINTRAC
Suspicious transaction reporting: when legal triage is needed
The STR decision turns on reasonable grounds to suspect, not proof — and the line between a compliance decision and a legal one is not always obvious.
- · FINTRAC
Transaction monitoring gaps in fintech compliance
The monitoring gaps most likely to produce FINTRAC findings are not technology failures — they are documentation and design failures.