From January 2026, Complium provides outsourced Compliance Officer services and full AML compliance support for FINTRAC-registered Money Services Businesses.
New from January 2026
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Complium now supports Canadian MSB compliance.
Following consistent demand from clients operating across both EU and Canadian jurisdictions, we expanded our anti-money laundering (AML) services to Canada at the start of 2026. We now provide outsourced Compliance Officer services and full AML programme support for FINTRAC-registered Money Services Businesses (MSBs).
If you hold a Canadian MSB licence, or are in the process of obtaining one, this page covers what the compliance obligation looks like under PCMLTFA and how Complium can cover it.
Who Needs a Compliance Officer Under PCMLTFA?
Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA, S.C. 2000, c. 17), every business registered with FINTRAC as a Money Services Business must appoint a Compliance Officer. This is not discretionary. Section 9.6 of PCMLTFA makes the appointment a mandatory element of the compliance programme, and FINTRAC treats the absence or inadequacy of a Compliance Officer as one of the most common examination findings.
FINTRAC may issue administrative monetary penalties of up to CAD 2,000,000 per violation under PCMLTFA ss. 73.1 to 73.23. Operating without a functional Compliance Officer is among the highest-risk gaps an MSB can have.
The obligation covers all FINTRAC-registered reporting entities, including:
- Canadian MSBs and foreign MSBs (fMSBs) registered with FINTRAC
- Crypto asset trading platforms and virtual currency dealers
- Payment service providers also registered under the Retail Payment Activities Act (RPAA)
- International fintech companies operating through a Canadian MSB licence
FINTRAC does not require the Compliance Officer to be a Canadian resident. However, most major Canadian financial institutions do, particularly during MSB banking onboarding. This distinction matters and is covered in the banking section below.
What the Compliance Officer Role Actually Covers
The Compliance Officer is personally accountable for the entity’s regulatory standing with FINTRAC. The role is active before the MSB begins operations and continues throughout the business lifecycle.
| Stage | Responsibility | Legal basis |
|---|---|---|
| Pre-operational | Design and document the AML/CTF compliance programme: KYC procedures, transaction monitoring rules, sanctions screening, record-keeping protocols | PCMLTFA s.9.6(1) |
| FINTRAC registration | Register as designated Compliance Officer with FINTRAC; complete banking onboarding AML questionnaires | PCMLTFR SOR/2002-184 |
| Ongoing operations | Supervise transaction monitoring, review alerts, file STRs, LCTRs, VCTRs and EFTRs within prescribed deadlines | PCMLTFA reporting obligations |
| Effectiveness review | Conduct the mandatory two-year programme effectiveness review | PCMLTFA s.9.6(2) |
| Training | Deliver AML/CTF training to directors, senior management and client-facing staff | PCMLTFA s.9.6(1) |
| FINTRAC examinations | Act as primary contact during compliance examinations; manage remediation of any findings | PCMLTFA examination provisions |
| Record-keeping | Maintain all required records for a minimum of five years | PCMLTFR record-keeping |
For MSBs dealing in virtual currencies, the scope extends to FINTRAC virtual currency transaction reporting (VCTRs) and FATF Travel Rule compliance for virtual asset transfers above the prescribed threshold.
Why Outsource? The Fractional Model Explained
Most international fintech companies operating through a Canadian MSB do not have Canadian employees. The compliance programme still needs to be in place from the date of registration. A fractional Compliance Officer resolves this gap: a qualified professional engaged on a monthly retainer who fulfils the full Compliance Officer role under PCMLTFA, without the cost or delay of a permanent hire.
| Model | Cost | Time to start | Best for |
|---|---|---|---|
| Full-time hire | CAD 80,000–150,000/year plus benefits | 4–12 weeks | High-volume mature MSBs with established Canadian operations |
| Fractional CO (outsourced) Recommended | Monthly retainer only, no employment costs | Immediate — same day as MSB registration | International operators, new MSBs, crypto exchanges, fintechs without Canadian staff |
| Internal / DIY | Low direct cost only if deep PCMLTFA expertise exists in-house | Immediate, but compliance gaps are common | Rarely viable for non-Canadian or early-stage operators |
The Compliance Officer cannot monitor or approve their own transactions. For small teams where the Compliance Officer is also involved in operations, this creates a practical conflict. An outsourced Compliance Officer provides independent oversight from day one.
The fractional model is particularly suited to:
- International fintech companies with a FINTRAC-registered MSB but no Canadian staff
- Companies that have acquired a ready-made MSB and need immediate compliance coverage from the transfer date
- Early-stage MSBs not yet generating the volume to justify a full-time hire
- Crypto exchanges and OTC desks requiring specialist knowledge of VCTR reporting and the FATF Travel Rule
What Complium Delivers
Complium has operated in the AML compliance space across the EU since 2008, working with regulated fintech companies, CASPs, EMIs and payment institutions. From January 2026, we extended this to Canadian MSBs following consistent demand from existing clients who hold, or are in the process of obtaining, a Canadian MSB licence alongside their EU licences.
Pre-operational set-up
Policies, procedures and controls covering client identification, KYC, ongoing due diligence, transaction monitoring, sanctions screening and record-keeping, aligned with PCMLTFA and FINTRAC guidance.
Registration with FINTRAC as the designated Compliance Officer for your MSB, with a signed scope of service agreement in place before commencement.
Completion of AML questionnaires required by Canadian financial institutions during account opening, and provision of compliance programme documentation as requested.
Design of client onboarding procedures, including identity verification methods, PEP and sanctions screening logic, and enhanced due diligence triggers.
Ongoing compliance operations
All ongoing Compliance Officer responsibilities are covered under the retainer: day-to-day oversight, FINTRAC report filing, regulatory update monitoring, staff training, and acting as the primary point of contact during any FINTRAC examination.
Before any engagement starts, Complium provides a formal service agreement defining scope, reporting obligations and fees. No compliance gap, no ambiguity about what is covered.
Banking and Local Substance
FINTRAC does not require the Compliance Officer to be a Canadian resident. In practice, however, most Canadian financial institutions expect one during MSB banking onboarding. This is the most common friction point for international operators, and it should be factored into the compliance set-up from the outset.
If banking access in Canada is a priority, the Compliance Officer arrangement needs to reflect that. Complium can advise on the right structure for your specific situation, including the combination of Compliance Officer, registered address and other substance elements that will satisfy both FINTRAC and your target banking partners.
MSBs operating in virtual currencies need to ensure their Compliance Officer has working knowledge of FINTRAC’s VCTR reporting requirements and the FATF Travel Rule as implemented in Canada. The reporting thresholds, timelines and data requirements differ from standard LCTR and STR obligations.
Frequently Asked Questions
Is a Compliance Officer mandatory for a Canadian MSB?
Yes. Under PCMLTFA s.9.6, every FINTRAC-registered MSB must appoint a Compliance Officer responsible for the AML/CTF compliance programme. The absence of a Compliance Officer is among the most frequently cited findings in FINTRAC examinations and can result in penalties of up to CAD 2,000,000 per violation.
Does the Compliance Officer need to be a Canadian resident?
FINTRAC does not require Canadian residency. However, most major Canadian financial institutions expect a Canadian-resident Compliance Officer as part of their MSB onboarding due diligence. The right structure depends on whether Canadian banking access is a priority for your business model.
Can Complium provide this service alongside an existing EU licence?
Yes. Many of our clients hold both an EU fintech licence (EMI, PI or CASP) and a Canadian MSB licence. We can coordinate AML compliance across both frameworks, which simplifies oversight and avoids duplication in policy documentation and training.
How quickly can the service be activated?
The outsourced Compliance Officer service can be activated on the same day as MSB registrations application gets submitted to the authorities or ready-made MSB transfer. A signed service agreement is in place before commencement. There is no recruitment process and no compliance gap at the point of transfer.
What happens during a FINTRAC compliance examination?
Complium acts as the primary point of contact with FINTRAC during any examination or assessment. This includes preparing examination documentation, responding to FINTRAC requests and managing any remediation required as a result of examination findings.
Does the service cover virtual currency reporting obligations?
Yes. For MSBs dealing in virtual currencies, the scope includes VCTR (Virtual Currency Transaction Report) filing and FATF Travel Rule compliance. These have distinct reporting thresholds and data requirements compared with standard transaction reporting.
