Support beyond the final report.
Every engagement includes a 90-day findings clarification session and our 12-month FINTRAC examination support commitment.
Meet FINTRAC’s two-year effectiveness review requirement through a risk-based, evidence-backed assessment of whether your AML program is current, appropriately designed and operating effectively in practice.
An effectiveness review should do more than confirm that policies exist. It should determine whether controls are current, appropriately designed and operating effectively in practice.
Independent AML Effectiveness Reviews
Answers to common questions about FINTRAC’s two-year effectiveness review requirement, review scope, testing, timing and what happens after the final report.
How often must an AML effectiveness review be completed?
Canadian reporting entities must generally complete and document an effectiveness review at least every two years. A review may also be appropriate following material changes to the organization, its products, systems, clients or risk profile.
What does an AML effectiveness review assess?
The scope depends on the organization and sector. It may include governance, policies and procedures, risk assessment, KYC and customer due diligence, beneficial ownership, ongoing monitoring, transaction reporting, training, recordkeeping, sanctions, ministerial directives and prior findings.
How does AlphaDelta determine the scope?
The review is tailored to the organization’s regulatory obligations, business model, risk profile, program maturity, material changes and previous findings. The scope, criteria, review period and testing approach are documented before fieldwork begins.
What testing may be performed?
Testing may include document review, interviews, walkthroughs, data analysis, file sampling and end-to-end testing. The objective is to assess whether controls are appropriately designed and operating effectively in practice.
How long does a review take?
Timing depends on the organization’s size, complexity, scope and readiness. A timetable is established during scoping and included in the engagement proposal. A typical review lasts 6-8 weeks.
Is the fee fixed?
Following the initial scoping discussion, AlphaDelta provides a defined scope, timetable and fixed professional fee for the engagement.
What will management receive?
The engagement includes a documented review plan, evidence-backed findings, risk-prioritized recommendations, a closing findings debrief and a final written report designed to support management’s regulatory and senior-officer reporting obligations.
What happens after the final report?
Every engagement includes an optional findings clarification session within 90 days. If FINTRAC formally initiates a compliance examination within 12 months of the final report, AlphaDelta also provides up to 10 hours of senior advisory support related to the review at no additional professional fee.
