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FINTRAC examinations are reviews (similar to an audit) of your compliance program and your operations (what you’re doing to stay in compliance). You will generally have 30 days to pull materials together and provide them to FINTRAC. It’s a good idea to read through the request carefully before you begin your preparation.
Whether you are submitting your materials on paper or in electronic format, it is a good idea to create folders or cover pages for each item that FINTRAC has requested. This creates separate sections for each item and helps you to stay organized. A missed item usually can’t be submitted once the deadline has passed, and can result in deficiencies in FINTRAC’s assessment. We’ve even created a sample format for your submission package that you can download and use free of charge!
Download the FINTRAC Examination Package Template.
Before you submit your final package, make sure that everything that FINTRAC has requested is included. If your materials require additional explanation, this should be provided with the package.
A portion of your exam will take place either over the phone or in person. It is fine to have your compliance program documents open during the exam (either on paper or electronically) and to refer to them. The examiner will start by asking you a series of questions about your business and move to specific questions about your compliance practices.
You will need to be able to describe the types of transactions that you are required to report to FINTRAC, the timeframes for reporting and your compliance practices. The examiner will also ask you about your risk assessment, your high risk clients, your enhanced due diligence (what you do differently if a client is high risk) and transaction monitoring.
Remember that during the exam is not the time to ask for clarification about what you should be doing. If you have questions of this nature, it’s a good idea to ask them before the exam or after it has ended. It is fine to ask for clarification about the questions that the examiner is asking if you aren’t sure what the examiner is looking for.
When the exam is complete, the examiner will let you know what deficiencies they’ve found. While you should not argue with the examiner, if there is information that they have missed, you can bring this to the examiner’s attention. You should take good notes during this section of the meeting. If there are many serious findings, you should ask the examiner if they expect to recommend a penalty.
After the examination, you will receive a formal letter that describes any deficiencies that the examiner has found. It is important to correct these as soon as you can. When FINTRAC finds the same deficiencies in a subsequent examination, they are more likely to recommend a penalty.
If you require assistance preparing for a FINTRAC exam, please contact us. There is no cost unless you enter into a formal agreement with us to provide services.
