Compliance program requirements

A program is more than a policy document

FINTRAC’s compliance-program guidance describes the core elements: a compliance officer, written policies and procedures, a risk assessment, an ongoing training program and an effectiveness review. The program must reflect the activities and risks of the business rather than just reproduce generic regulatory language.

Connect the risk assessment to actual controls

Assess customers and relationships, products and delivery channels, geographic exposure and other relevant business risks. Explain how those risks affect identification, monitoring, escalation and recordkeeping. Where higher risk is identified, document the measures used to address it.

Allocate responsibilities between customer operations, compliance and technology providers. Outsourcing a task does not make a policy implement itself: staff need procedures, access to records and a clear escalation route.

Review whether the program works

The effectiveness review must take place at least every two years. Use the official guidance to plan its scope and independence requirements. Test implemented controls, document findings and track remediation. Training records and approved policies are evidence of activity, but not conclusive evidence that the controls are effective.