The two-year effectiveness review: a checklist

Guide · Updated 11 October 2026 · 3 min read · AML Canada

What FINTRAC requires from your review, what to test, and how to report it, in a checklist you can work through.

Key points

  • Review every part of your compliance program at least every two years.
  • An internal or external auditor does it, or you, if you have no auditor.
  • Report the findings in writing to a senior officer within 30 days.
  • Test what actually happens, not just whether documents exist.

Questions

Still not sure? Book a consultation or write to info@amlcanada.ca.

How often is an AML effectiveness review required?

At least every two years.

Who can do the effectiveness review?

An internal or external auditor, or yourself if you don't have an auditor. FINTRAC suggests it shouldn't be someone directly involved in the activities being reviewed.

What happens after the review?

Report the findings in writing to a senior officer within 30 days, along with the updates made to policies and procedures and how far they've been put in place.

See what moves. Report what matters.

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