effectivenessreviewsthatkeepyourregistrationintactandyourbanksatisfied.
Under the PCMLTFA, every reporting entity must have an independent assessment of their compliance program's effectiveness at least once every two years. This is Pillar 5 of the FINTRAC compliance framework — and it's one of the first things FINTRAC and banking partners look for.
whythismattersnow.
The compliance environment has tightened significantly. Programs that were adequate at registration may no longer meet current FINTRAC expectations, and both regulators and banking partners are demanding proof.
- FINTRAC revoked 86 MSB registrations in Q1 2026, many for program deficiencies
- Banks increasingly demanding effectiveness reviews as a condition of keeping MSB accounts open
- Armoured car companies’ first reviews are due mid-2026
- Compliance programs written before 2023 and not formally reviewed are almost certainly deficient relative to current PCMLTFA obligations
howwehelp.
Three approaches depending on what your situation requires — from conducting the review directly to managing the process with an external firm.
Direct review
We assess your policies, procedures, risk assessments, training records, reporting accuracy, and overall program effectiveness against current FINTRAC expectations. A thorough, independent evaluation.
Liaison service
If your bank requires a review from a Big 4 firm or specific approved reviewer, we act as your internal compliance liaison — sourcing the right reviewer, preparing documentation, and fielding questions throughout the process.
Remediation
Post-review, we implement the findings — policy updates, procedure changes, training gaps, reporting fixes. Not just a report, but actual program improvement that makes your next review cleaner.