Running a Money Services Business (MSB) in Canada means more than just moving money. It means taking responsibility for keeping the financial system safe from money laundering and terrorist financing. That’s why every MSB must have a compliance program that meets the requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).If you’ve ever asked yourself what does a FINTRAC MSB compliance program include or wondered how to get started, this guide breaks down FINTRAC’s Guide 4 into plain, practical steps.
Governance and Roles
The first building block of a compliance program is governance. In simple terms, this means setting clear responsibilities for who does what and making sure oversight is strong.
At the heart of governance is the compliance officer. FINTRAC requires every MSB to designate one. If you are asking how to appoint a compliance officer for an MSB, the answer is straightforward: choose someone with enough authority and independence to do the job. This person cannot be buried in operations without decision-making power. They must be able to escalate issues directly to ownership or the board.
A good compliance officer does not work alone. MSBs should assign control owners for each of the main program areas:
- Know Your Client (KYC) processes
- Reporting suspicious or large transactions
- Record keeping
- Employee training
- Program testing and review
By distributing responsibilities, the compliance officer can focus on oversight instead of being pulled into daily operations. Many MSBs find it useful to form a small compliance committee. Even if your business is small, you can hold quarterly meetings, document key discussions, and record decisions in minutes. This creates accountability and shows FINTRAC that compliance is not just a formality—it is part of how you run your business.
Comply North offers Chief Compliance Officer as a Service for MSBs that need professional, reliable oversight without hiring full-time staff. It is the best in the industry, with direct FINTRAC experience and the best price in Canada.
Policies, Procedures, and Training
The next piece of a compliance program is converting legal obligations into practical instructions staff can follow. Many MSBs struggle here. It is not enough to copy and paste the law into a manual. Employees need clear step-by-step procedures.
So, do MSBs need written AML policies in Canada? Yes, absolutely. FINTRAC requires written policies and procedures that explain how your MSB will meet its obligations. These documents should cover client identification, reporting requirements, record keeping, risk assessment, training, and ongoing monitoring.
For example:
- A KYC checklist can walk staff through what identification is acceptable, how to verify it, and what to do if something looks suspicious.
- A reporting standard operating procedure (SOP) can outline how to prepare and submit suspicious transaction reports (STRs) or large cash transaction reports (LCTRs) to FINTRAC.
Document control is also critical. Policies should be versioned, dated, and stored in a central location where employees can access the most current version. Old policies should be archived to avoid confusion.
Training is another non-negotiable. If you are wondering what training is required for MSB employees under FINTRAC, the rule is that all staff must be trained on compliance obligations relevant to their role. New hires should be trained before they start handling transactions, and everyone should receive refresher training at least once a year. Training should be documented, with attendance records and test results kept on file.
At Comply North, we help MSBs build customized training programs that are easy to understand and directly aligned with FINTRAC’s expectations.
For more detail, you can review FINTRAC’s compliance program guidance.
Two-Year Effectiveness Review and Testing
Even the best-designed compliance program can drift over time. That is why FINTRAC requires a documented review at least every two years. If you are asking how often must MSBs review their compliance program, the answer is clear: at minimum, once every two years, though more frequent reviews are encouraged for higher-risk businesses.
So, what is a two-year effectiveness review for MSBs? It is a structured evaluation of whether your compliance program is working as intended. The review should be independent—either done by someone not involved in daily compliance operations or by an external consultant. Smaller MSBs sometimes have internal staff perform the review, but using an independent reviewer adds credibility and often uncovers issues that insiders miss.
The review should cover:
- The effectiveness of reporting (Are suspicious transactions reported on time? Are all large transactions captured?)
- The quality of KYC files (Are documents properly verified? Are red flags noted?)
- Monitoring processes (Are high-risk clients and transactions reviewed as required?)
- Record keeping (Are all required records complete and accessible?)
- Training outcomes (Do staff understand and apply procedures correctly?)
A sample plan might include testing a batch of transaction reports to confirm timeliness, reviewing client files for completeness, and checking monitoring alerts against outcomes. Findings should be tracked, with assigned owners and deadlines for remediation.
If you are wondering how do I test an MSB compliance program, start small: pick three key areas such as reporting, KYC, and monitoring. Test them thoroughly, document results, and fix weaknesses. Then expand your scope over time.
Comply North provides independent effectiveness reviews tailored for MSBs. With direct FINTRAC experience, we know what regulators look for and can help you close gaps before an audit.
For FINTRAC’s official expectations, see Effectiveness Reviews under Guide 4.
Why This Matters
Compliance programs can feel overwhelming, but they are not optional. FINTRAC audits MSBs regularly, and penalties for gaps can be severe. A strong program protects your business, your clients, and Canada’s financial system.
The good news is you do not have to build it alone. Comply North specializes in MSB registration support, compliance officer services, and independent reviews. We provide the professional, reliable support your MSB needs to stay ahead of FINTRAC requirements, all at the best price in the industry.
If you are ready to strengthen your compliance program, contact Comply North today.
