Outsourced Compliance Officer

your named compliance officer. embedded with your team, not billing from a distance.

FINTRAC requires every MSB to appoint a compliance officer responsible for implementing the program. For most small MSBs, that means the founder is wearing the hat — and FINTRAC expects that person to actually know what they're doing.

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thegap.

FINTRAC expects your compliance officer to have authority and resources to implement the program, working knowledge of your business structure and operations, understanding of sector-specific ML/TF risks and typologies, and fluency with PCMLTFA obligations. Most small MSB operators don't meet that bar — and FINTRAC is enforcing harder than ever.

86 MSB registrations revoked in Q1 2026 alone — many for program deficiencies
Banks demanding compliance evidence just to keep accounts open
Policies written at registration are almost certainly deficient by current standards
Hiring a full-time compliance officer costs $120K+ before you add benefits and training

whatyouget.

A named, CAMS-certified compliance officer who serves as your CAMLO of record. Not a strategy deck — an embedded operator.

Named CAMLO on your FINTRAC registration

A designated Compliance Officer who serves as your primary FINTRAC point of contact — with the authority, knowledge, and CAMS certification that FINTRAC expects.

AML/ATF program design & maintenance

Written policies and procedures, quarterly reviews alongside management, and a documented risk assessment updated monthly internally and quarterly with your team.

FINTRAC reporting via Comply+

Transaction reporting handled through Comply+ — structured, accurate, and efficient. LCTRs, STRs, and EFTRs filed correctly and on time, every time.

Banking partner liaison

Banks increasingly demand compliance evidence to keep MSB accounts open. We handle the documentation, communication, and relationship management that keeps your banking intact.

whorunsyourcompliance.

provides strategic oversight, regulatory positioning, and fintech-specific guidance. As former CFO & CCO of a publicly listed crypto company, he built compliance programs from the ground up. handles day-to-day compliance execution — policies, controls, training, audit readiness, and FINTRAC reporting oversight. Together with Comply+ for transaction reporting, that's a complete compliance function at a fraction of a full-time hire.

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.

questionswegetasked.

What is a fractional compliance officer?

A fractional or outsourced compliance officer is a CAMS-certified specialist who acts as the named compliance officer on your FINTRAC registration, part time. You get the AML program, reporting oversight and bank conversations handled without hiring someone full time.

Can an outsourced compliance officer be the named CAMLO on my FINTRAC registration?

Yes. That is the core of this service. We are named on your registration as your compliance officer and deal with FINTRAC directly. Your business stays responsible for compliance as the reporting entity, so we report to your owner or board.

Who needs a fractional compliance officer in Canada?

Small and mid-sized MSBs, crypto dealers, foreign exchange dealers and armoured car companies that need a qualified compliance officer but not a $120K+ full-time hire. It also fits if the founder holds the role today and FINTRAC or your bank has started asking harder questions.

What does an outsourced compliance officer cost?

A fixed monthly retainer scoped to your volume, products and reporting load, at a fraction of a full-time hire. For the full breakdown, read what an outsourced compliance officer costs a Canadian MSB.

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