As of mid-2026
FINTRAC's Most Wanted
Failure to institute and document the prescribed review
Welcome back! We've hit the top four of our FINTRAC's Most Wanted series where we're tracking monetary penalties since the beginning of last year, and this is where the penalties start to get heavy.
Number Four on the list is: "Failure to institute and document the prescribed review."
Last year, 10 companies were hit with this and in plain English, this means they forgot to audit themselves or have someone else do it.
In Canada you're required to review your AML program for efficacy every two years, and you need to document any deficiencies that come up and create a plan to close any gaps.
Scheduling the review is easy but you have to prove that your system actually works, so most CAMLOs dread the audit because you're not 100% sure how the rules will perform under pressure.
If you're just hoping that your transaction monitoring is catching the right things, you're probably not ready for a review and you're going to uncover surprises.
So full disclosure, Rhizome can't perform your independent review for you. We have partners that are really capable at this and that we can refer you to, but we do make it incredibly easy for you to prepare for an audit and pass it.
We do this by providing you with a full compliance sandbox, where you're free to upload new rules, upload transactions, tweak existing rules, and delete and retry until you are comfortable with the way things are working.
You just rinse, lather, repeat your efficacy testing until you're confident.
That way when an auditor arrives and they ask how you know your system is effective, you don't have to guess you can actually show them the results or invite them to investigate themselves.
Show them the results from your sandbox trials, show them how certain rules are being applied and you're gonna pass with flying colors.
Whether it's an internal audit, external audit, or even an audit from regulators!
Reach out to us to see how we can help with the rest of your compliance program.