don'twaitforthereviewertofindthegaps.wefindthemfirst.
Most MSBs treat the effectiveness review as a checkbox exercise — hire a reviewer, hope for the best, scramble to fix whatever comes back. The smarter approach: identify and close the gaps before the reviewer walks in.
therisk.
Reactive remediation means extended timelines, a second round of review costs, and the possibility that your bank sees deficiencies before you've had a chance to fix them. Programs that haven't been formally reviewed since registration are almost certainly deficient by current standards.
- Policies that don’t reflect how your business actually operates today
- Risk assessments that haven’t been updated since initial registration
- Training records that show a one-time event from two years ago, not ongoing development
- Missed or incomplete FINTRAC reports that a reviewer will flag immediately
- Record keeping gaps that violate the five-year retention requirement
whatreadinesslookslike.
An internal pre-review — a gap analysis against what FINTRAC examiners and external reviewers actually look for. Ideally started 2\u20133 months before your review deadline.
Policy & procedure review
Are your written policies up to date with current PCMLTFA requirements? Do they reflect how your business actually operates, or are they boilerplate from when you registered?
Risk assessment validation
Is your risk assessment documented, current, and reflective of your actual business activities, products, clients, and geographies?
Training & reporting audit
Can you demonstrate that all relevant staff have been trained on an ongoing basis? Are your LCTRs, STRs, and EFTRs being filed correctly, on time, and with complete information?
Gap remediation
We close the gaps before your formal review — policy updates, procedure changes, training gaps, and reporting fixes. Your formal review is cleaner, faster, and cheaper.