Independent effectiveness reviews
The biennial review FINTRAC mandates — an objective, independent test of whether your compliance program actually works. Delivered with a documented gap analysis and a prioritized remediation plan, performed independently of the functions under review.
Required every two years — and the first thing an examiner asks for
The PCMLTFA requires a review of your compliance program at least every two years, conducted independently of the people who run it. It must test your policies and procedures, your risk assessment, and your training program, and judge whether the program is effective in practice. A missing or stale review is one of the most common examination findings — and one of the easiest to avoid.
A genuine test — not a rubber stamp
We review the whole program against the current requirements, sample what is actually happening, and report findings you can act on before FINTRAC does.
Policies & procedures testing
Risk-assessment review
Training-program evaluation
Transaction & reporting sampling
Interviews
Governance & oversight
A structured, defensible review
Scoping
We agree the period, lines of business, and methodology up front.
Document review
We examine policies, the risk assessment, and training records.
Testing
We sample transactions, reports, and records for real evidence.
Interviews
We talk to the compliance officer and front-line staff.
Reporting
We deliver findings, a gap analysis, and a remediation plan.
Due for your two-year review?
Book a free consultation and we’ll scope an independent effectiveness review that satisfies FINTRAC and tells you the truth about your program.