advisoryaicontact
FX Dealer Compliance

foreign exchange compliance. built for dealers who move money, not paperwork.

Foreign exchange dealers are classified as MSBs under the PCMLTFA and face the full suite of FINTRAC obligations. FX-specific risks around large cash transactions, cross-border transfers, and structuring patterns require sector-specific compliance knowledge.

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therequirements.

FX dealers face unique compliance challenges that generic programs don't adequately address. Large cash volumes, cross-border transfers, walk-in customers, and structuring risk all require tailored controls and monitoring.

  • FINTRAC MSB registration and biennial renewal
  • Named compliance officer (CAMLO) with authority to implement the program
  • Large cash transaction reporting for $10,000+ thresholds
  • EFT reporting for cross-border transfers
  • Suspicious transaction reporting and third-party determination
  • PEP and sanctions screening for all customers
  • Record keeping for a minimum of five years

whatweprovide.

The same outsourced compliance model, positioned specifically for FX dealer operations.

Named CAMLO & AML/ATF program

A CAMS-certified compliance officer on your FINTRAC registration with AML/ATF policies and procedures tailored specifically to foreign exchange operations.

Transaction reporting

Large cash transaction reports ($10,000+ threshold), EFT reports for cross-border transfers, and suspicious transaction reports — all filed through Comply+ for accuracy and timeliness.

KYC framework for FX operations

Client identification and verification procedures for walk-in and recurring customers, third-party determination requirements, and PEP and sanctions screening.

Risk assessment & effectiveness reviews

Documented risk assessment reflecting your actual FX activities, products, clients, and geographies. Biennial effectiveness review coordination and preparation.

yourcomplianceteam.

provides strategic oversight and regulatory positioning, with deep experience in treasury management and financial compliance across regulated entities. handles day-to-day compliance execution — AML program management, KYC oversight, FINTRAC reporting, and staff training. Together with Comply+ for automated reporting, that's a complete compliance function for your FX operations.
CPACFACAMS
Luke ThibodeauCPA · CFA · CAMSFounder and CEO

Luke is a finance and compliance operator who works hands-on with bitcoin-native companies, fintechs, and MSBs as a fractional CFO and CCO through Rockwell Advisory Group. As former CFO & CCO of Bitcoin Well (TSXV:BTCW), he built and ran the finance, compliance, and governance functions across a publicly listed, multi-entity crypto company from the ground up.

Today he brings that same operational depth to clients navigating treasury management, FINTRAC compliance, financial reporting, and corporate governance. Whether it's standing up a compliance program for a new MSB, managing multi-entity consolidations, or advising on AI strategy through Rockwell AI, Luke operates as an embedded member of the team rather than an outside advisor. He also founded Comply+, a RegTech platform automating FINTRAC reporting for Canadian MSBs, born directly from the pain points he encountered building compliance workflows by hand.

Charles KlineCAMSHead of Compliance

Charles leads compliance and risk for Rockwell Advisory Group, helping fintechs, MSBs, and payments companies build AML and KYC programs, tighten onboarding and monitoring, and stay aligned with FINTRAC and Canadian regulatory expectations. CAMS-certified, he works as an embedded operator: policies, controls, training, audit readiness, and the day-to-day execution that backs them up.

Previously he served as Compliance Officer and Director of Risk & Compliance at Peloton Technologies, running the enterprise AML program (including FCAC and RPAA), leading the RPAA roll-out for a large organization, training analysts on KYC, sanctions, and FINTRAC reporting, leading the first external Compliance Effectiveness Review, and rebuilding onboarding for FINTRAC KYC. Before that he was Head of Underwriting & Risk at Orchard Technologies, building PayFac-ready underwriting and AML frameworks and automated onboarding from early stage through Global Payments partnership. At Lightspeed Commerce (Payments), he scaled underwriting from a solo function to a global team of twenty across North America, EMEA, and APAC while keeping fraud losses below industry benchmarks.

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