CAMLO & MLRO · Canada

Outsourced CAMLO & MLRO Services for Canadian MSBs

Your MSB needs a compliance officer who actually knows what they're doing - not a name on paper. An unqualified CAMLO or an absent MLRO won't protect you when FINTRAC examines your business or when a suspicious transaction needs to be reported in hours, not weeks. We provide experienced, hands-on compliance officers who take real accountability for your MSB.

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The Stakes

Under the PCMLTFA, every Canadian MSB must appoint a CAMLO - and the person in that role carries personal responsibility for your entire compliance program.

This isn't a ceremonial title. The CAMLO is the individual FINTRAC holds accountable for the design, implementation, and effectiveness of your AML/ATF program. If your compliance program fails examination, if suspicious transactions go unreported, if your risk assessment is outdated - it's the CAMLO's responsibility. And by extension, your business that faces the consequences.

The MLRO carries a different but equally critical function: receiving internal disclosures, assessing whether activity is genuinely suspicious, making the decision to file STRs and TPRs with FINTRAC, and ensuring reports are accurate and timely. A delayed or poorly filed STR can trigger enforcement action on its own.

Many MSBs treat these roles as formalities - appointing someone who lacks the experience, training, or availability to actually perform the function. FINTRAC doesn't see it that way. During an examination, they will interview your compliance officer, test their knowledge, and evaluate whether they're genuinely overseeing your program or simply occupying a title.

We provide outsourced CAMLO and MLRO services with professionals who have operated MSBs themselves and know what FINTRAC expects - not in theory, but from direct experience.

What Goes Wrong

Why MSBs struggle with compliance officer roles

Name-Only Appointments

Appointing a director or employee as CAMLO because someone needs to fill the role - without the training, experience, or time to actually oversee compliance. FINTRAC will interview this person during an examination. If they can't explain your compliance program in detail, your MSB fails.

No AML/ATF Expertise

The CAMLO needs deep knowledge of the PCMLTFA, FINTRAC guidance, risk assessment methodology, KYC requirements, and reporting obligations. An accountant, lawyer, or operations manager without specific AML training cannot perform this role effectively - and FINTRAC will identify the gap immediately.

Delayed STR Filing

When suspicious activity is detected, the clock starts ticking. STRs must be filed with FINTRAC within 30 days. Without a dedicated MLRO who can assess activity quickly and make filing decisions, reports get delayed or missed entirely - exposing your MSB to administrative monetary penalties and potential criminal referrals.

No Separation of Roles

The CAMLO oversees the entire compliance program. The MLRO handles day-to-day reporting. When one person tries to do both - while also running other aspects of the business - quality suffers. Compliance oversight becomes reactive instead of proactive, and critical tasks fall through the cracks.

Hiring Costs

A qualified, full-time compliance officer in Canada commands a significant salary - often $80,000 to $150,000+ depending on experience. For early-stage or mid-size MSBs, this cost is prohibitive. But the alternative - an unqualified person in the role - is even more expensive when FINTRAC comes knocking.

Regulatory Consequences

FINTRAC doesn't issue warnings for compliance officer deficiencies. They issue findings, penalties, and in serious cases, criminal referrals. A CAMLO who can't demonstrate oversight of the compliance program, or an MLRO who can't show proper STR assessment processes, puts your entire MSB registration at risk.

Understanding the Roles

CAMLO vs. MLRO - two distinct functions

CAMLO

Chief Anti-Money Laundering Officer

The CAMLO is responsible for the strategic oversight of your entire AML/ATF compliance program - its design, implementation, maintenance, and effectiveness.

  • • Owns the compliance program end-to-end
  • • Ensures policies and procedures are current and effective
  • • Oversees risk assessment methodology and updates
  • • Manages staff training program
  • • Coordinates the two-year effectiveness review
  • • Primary point of contact for FINTRAC examinations
  • • Reports to senior management on compliance status

MLRO

Money Laundering Reporting Officer

The MLRO handles the operational side of compliance reporting - receiving internal disclosures, assessing suspicious activity, and filing regulatory reports with FINTRAC.

  • • Receives and evaluates internal suspicious activity reports
  • • Makes the decision to file or not file STRs
  • • Prepares and submits STRs and TPRs to FINTRAC
  • • Monitors transaction alerts and escalations
  • • Maintains reporting records and documentation
  • • Ensures reporting timelines are met
  • • Liaises with FINTRAC on report-related inquiries

What's Included

Comprehensive outsourced compliance officer services

Outsourced CAMLO

A named, experienced compliance officer who takes formal responsibility for your AML/ATF program - overseeing policies, risk assessment, training, and effectiveness reviews on an ongoing basis.

Outsourced MLRO

A dedicated reporting officer who receives internal disclosures, evaluates suspicious activity, and files STRs and TPRs with FINTRAC - ensuring your reporting obligations are met accurately and on time.

Compliance Program Oversight

Ongoing review and maintenance of your compliance program - ensuring policies remain current with FINTRAC guidance updates, PCMLTFA amendments, and changes in your business operations.

Transaction Monitoring Review

Regular review of flagged transactions, alert escalation decisions, and monitoring thresholds - ensuring your transaction monitoring system is actually catching what it should be catching.

Staff Training Delivery

AML/ATF training for your team - covering compliance obligations, red flag indicators, internal reporting procedures, and role-specific responsibilities. Training records maintained for FINTRAC examination.

FINTRAC Examination Support

Full preparation for FINTRAC examinations - document review, gap analysis, mock interviews, and on-site support during the examination itself. Your CAMLO will be ready to answer every question FINTRAC asks.

Regulatory Updates

Continuous monitoring of PCMLTFA amendments, FINTRAC guidance changes, and regulatory developments that affect your MSB - with proactive updates to your compliance program as requirements evolve.

Effectiveness Review Coordination

Management of the mandatory two-year compliance program effectiveness review - including scoping, testing, reporting, and remediation tracking to ensure your program meets FINTRAC's standards.

Get Started

Your CAMLO will be interviewed by FINTRAC

During a compliance examination, FINTRAC doesn't just review documents - they interview the person responsible for your program.

Your CAMLO needs to explain how the risk assessment was conducted, how KYC procedures work in practice, how suspicious activity is detected and reported, and how the compliance program is maintained. If they can't answer confidently and in detail, FINTRAC will issue deficiency findings.

Our outsourced CAMLOs have sat through these examinations before - with their own MSBs. They know the questions, they know the expectations, and they know how to demonstrate that your program is real, not just documentation.

Appoint an Experienced CAMLO

Who This Is For

  • • Newly registered MSBs that need a qualified compliance officer from day one
  • • MSBs whose current CAMLO lacks AML/ATF expertise or availability
  • • Early-stage businesses that can't justify a full-time compliance hire
  • • Crypto exchanges and fintech companies with complex reporting obligations
  • • MSBs preparing for or recovering from a FINTRAC examination
  • • International founders who need a Canada-based compliance officer
  • • MSBs looking to transition from outsourced to in-house and need training support

How It Works

From engagement to active compliance oversight

01

Assessment

We review your current compliance program, business model, and operational structure to understand your CAMLO and MLRO needs and identify any immediate gaps.

02

Appointment

Formal appointment of your outsourced CAMLO and/or MLRO, including all required documentation, internal notifications, and FINTRAC registration updates if applicable.

03

Integration

Your compliance officer integrates with your team and systems - reviewing policies, calibrating monitoring processes, establishing reporting workflows, and identifying any program improvements.

04

Ongoing Oversight

Continuous compliance management - program oversight, regulatory reporting, staff training, FINTRAC correspondence, and proactive updates as regulations and your business evolve.

Why BEMSB

We don't provide compliance officers who read about MSBs. We provide compliance officers who've run them.

Our outsourced CAMLOs and MLROs come from an operational background. They've built compliance programs, sat through FINTRAC examinations, filed STRs under real time pressure, and managed banking relationships where compliance was the deciding factor between keeping and losing the account.

That practical experience matters because compliance isn't just about documentation - it's about judgment. When is a transaction genuinely suspicious versus unusual but explainable? How do you calibrate monitoring thresholds for a new business with no historical data? What does FINTRAC actually focus on during an examination versus what the guidance says they might look at?

These are questions that can only be answered by someone who's been in the room. Our compliance officers have been in the room - many times. They bring that experience to every MSB they oversee, and it shows in the quality of their work and the outcomes for our clients.

When FINTRAC interviews your CAMLO, they'll be speaking with someone who knows exactly what to say - because they've lived it.

Frequently Asked Questions

CAMLO & MLRO services for MSBs

A CAMLO (Chief Anti-Money Laundering Officer) is the person designated as responsible for the implementation and oversight of your MSB's AML/ATF compliance program. Under the PCMLTFA and its associated regulations, every Canadian MSB must appoint a compliance officer. This person must have the authority and resources to effectively manage the program, and they carry personal accountability for its adequacy. The CAMLO role is not optional - it's a legal requirement that FINTRAC examines closely.
The CAMLO focuses on strategic compliance oversight - the design, implementation, and effectiveness of the overall AML/ATF program. The MLRO focuses on operational compliance reporting - receiving internal disclosures, assessing suspicious activity, and filing regulatory reports (STRs, TPRs) with FINTRAC. In smaller MSBs, both functions are sometimes performed by one person, but as your business grows, separating these roles improves both the quality of oversight and the speed of reporting. We offer both roles independently or as a combined service.
Yes. The PCMLTFA allows MSBs to outsource compliance functions, including the CAMLO role, to qualified third parties. However, the responsibility for compliance ultimately remains with the MSB itself. This means your outsourced CAMLO must be genuinely involved in overseeing your program - not just named on paper. FINTRAC will verify this during examinations. Our outsourced CAMLOs maintain active involvement in every MSB they serve, with regular reviews, training, and direct engagement with your team.
Your outsourced CAMLO integrates with your business through regular reviews of compliance operations, transaction monitoring oversight, staff training delivery, policy updates, and ongoing communication with your team. They're available for time-sensitive decisions - STR assessments, regulatory correspondence, incident response - and conduct scheduled reviews of your program's effectiveness. During FINTRAC examinations, your CAMLO participates directly, answering examiner questions and demonstrating program oversight. It's a hands-on relationship, not a passive arrangement.
FINTRAC will request to interview your CAMLO as part of the examination process. They'll ask about the structure of your compliance program, how risk assessments are conducted, how policies are implemented, how staff training is delivered, and how the program's effectiveness is reviewed. They'll test whether your CAMLO has genuine oversight or is simply a name in the documentation. Our outsourced CAMLOs are fully prepared for these interviews - they can speak in detail about every aspect of your program because they actively manage it.
For most early-stage and mid-size MSBs, significantly so. A qualified full-time compliance officer in Canada typically costs $80,000 to $150,000+ in salary alone, plus benefits, training, and management overhead. Our outsourced services provide the same level of expertise and availability at a fraction of that cost - and you benefit from our experience across multiple MSBs, which means broader regulatory knowledge and faster response to emerging compliance issues. As your business grows, we can also help you transition to an in-house compliance function when the time is right.
Yes. We offer transition support for MSBs that want to move from outsourced to in-house compliance management. This includes identifying the right candidate within your team, providing comprehensive AML/ATF training, mentoring them through their first compliance cycle, and ensuring a clean handover of all oversight responsibilities. We stay available for advisory support after the transition, so your new CAMLO has experienced backup when they need it.

Get In Touch

Need an experienced CAMLO or MLRO for your MSB?

Start with a free 30-minute consultation. We'll assess your compliance officer needs, explain how outsourced CAMLO and MLRO services work, and outline a plan that fits your business.

Office 638, 145 1/2 Church Street, Unit 5
Toronto, Ontario, M5B 1Y4, Canada
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