AML Audit and Effectiveness Review in Canada
Request an AML ReviewIndependent testing to confirm your AML controls work in practice and meet FINTRAC requirements.
INDEPENDENT AML REVIEW
Independent AML Audits That Test What Works in Practice
FINTRAC reporting entities must review the effectiveness of their AML compliance arrangements at least every two years.
The review should test whether policies, risk assessments, client due diligence, training, reporting processes and internal controls operate effectively in practice. It should not simply confirm that documentation exists.
Complium performs independent, risk-based testing and provides management with documented findings, supporting evidence and clear remediation priorities.
Full AML Effectiveness Review
Review governance, policies, risk assessment, controls and implementation across the business.
Client Due Diligence Review
Test client identification, beneficial ownership, risk classification, enhanced measures and ongoing monitoring.
Transaction Monitoring and Reporting Review
Review transaction monitoring, escalation, recordkeeping and applicable FINTRAC reporting processes.
Follow-Up and Remediation Review
Verify whether previous findings and corrective actions have been addressed effectively.
The review scope is tailored to the reporting entity, business model, risk profile, regulatory obligations and changes since the previous review.
-
STEP 1
Scope and
We define the requirements, risk areas, evidence, samples, interviews and documents needed for a focused review.
Planning -
STEP 2
Independent
We test how governance, client due diligence, monitoring, reporting, training and controls operate across the business.
Testing -
STEP 3
Audit Report and
Management receives documented findings, risk ratings, supporting evidence, clear recommendations and priorities for corrective action.
Remediation Plan
EFFECTIVENESS REVIEW SCOPE
What the AML Audit Can Cover
An AML audit tests whether compliance controls are properly designed and operating effectively in practice.
The scope is tailored to the reporting entity, services, risk profile, previous findings and regulatory obligations.
Governance and Accountability
Review Compliance Officer responsibilities, management oversight, escalation arrangements and internal reporting.
Policies and Risk Assessment
Assess whether AML policies, procedures and the business-wide risk assessment remain accurate, current and aligned with the operating model.
Client Due Diligence
Test client identification, beneficial ownership, risk classification, enhanced measures and ongoing monitoring.
Transaction Monitoring and Escalation
Review monitoring processes, alerts, internal escalation, higher-risk activity and documented decision-making.
FINTRAC Reporting and Records
Test regulatory reporting processes, recordkeeping, supporting evidence and internal responsibilities.
Training and Previous Remediation
Review AML training records, staff understanding and the status of corrective actions from previous reviews or compliance findings.
The review combines document analysis, interviews and sample testing to produce an evidence-based assessment rather than a checklist exercise.
KEY BENEFITS
Clear, Independent and Actionable Results
An independent AML audit gives management a clear view of whether controls operate as intended, where weaknesses exist and which corrective actions should take priority.
Independent Insight
Receive objective testing from experienced AML specialists with legal and operational knowledge.
FINTRAC-Aligned Review
Assess the AML requirements and controls relevant to the reporting entity and its risk profile.
Clear Remediation Plan
Receive documented findings, risk ratings and practical recommendations for corrective action.
A clear audit report helps management demonstrate oversight, allocate resources and track remediation effectively.
WHO WE SUPPORT
Independent AML Reviews for Canadian Reporting Entities
The service is designed for Canadian and Foreign MSBs and other reporting entities that require independent testing of their AML compliance arrangements.
Canadian
MSBs
Foreign
MSBs
Virtual Currency
Businesses
Payment and Fintech
Businesses
The applicable review requirements and scope depend on the reporting entity, activities and regulatory framework.
WHY COMPLIUM
Independent AML Review
with Practical Expertise
Complium combines independent testing with practical experience in AML governance, client due diligence, transaction monitoring, regulatory reporting and remediation.
-
Review Scope and
Planning -
AML Framework and Risk
Assessment Review
-
KYC and Beneficial
Ownership Testing -
Monitoring, Reporting
and Records
-
Management Report and
Remediation Plan -
Follow-Up Review
Support
Our international legal and compliance team has supported more than 500 fintech and regulated projects across 46+ countries.
CONTACT US
Plan Your AML
Effectiveness Review
Tell us about the reporting entity, services, current AML compliance framework and date of the previous review. We will define the appropriate scope and evidence plan.
FREQUENTLY ASKED QUESTIONS
AML Audit and Effectiveness Review FAQs
Practical answers about AML audits, FINTRAC two-year effectiveness reviews, testing scope, evidence, reporting and remediation.
An AML effectiveness review is a documented assessment of whether the AML compliance framework operates effectively in practice. It tests the design and implementation of policies, risk assessment, training and relevant controls to identify gaps or weaknesses.
FINTRAC reporting entities must carry out an effectiveness review at least every two years. The next review must begin no later than 24 months from the start of the previous review, and the previous review must be completed before the next one begins.
FINTRAC permits the review to be conducted by an internal or external auditor, or by the reporting entity itself where it does not have an auditor.
The reviewer should understand the applicable requirements. FINTRAC also identifies impartiality as a best practice, so the reviewer should not be directly involved in the compliance activities being assessed.
Not always. AML audit is a broader term for an independent assessment of AML controls. A FINTRAC two-year effectiveness review is a specific regulatory assessment that must be completed at least every two years.
Complium can structure one engagement to meet the FINTRAC effectiveness review requirements while also testing the wider AML controls relevant to the business.
The scope can include governance, policies, risk assessment, client due diligence, transaction monitoring, escalation, FINTRAC reporting, recordkeeping, training and previous remediation work.
Evidence may include policies, risk assessments, training records, client files, transaction or alert samples, reporting records, management information and previous review findings.
The exact evidence plan is agreed during scoping.
The review scope and testing approach reflect the reporting entity, services, size, complexity, customer profile, transaction activity, risk assessment and regulatory obligations.
Management receives a documented report setting out the review scope, testing performed, findings, supporting evidence, risk ratings and practical remediation priorities.
Yes. Complium can help management prioritize corrective actions, strengthen controls and verify whether agreed remediation has been implemented effectively.
Responsibility for compliance remains with the reporting entity and its management.
The timeline depends on the review scope, business complexity, sample sizes, document readiness and access to relevant staff and records.
Complium confirms the expected timetable after the initial scoping assessment.
Couldn’t find your answer? Ask a question
