What FINTRAC expects of a compliance officer
Appointing a compliance officer is the first of the five parts of a compliance program. The person must have the necessary authority and access to resources to implement an effective program, and FINTRAC's best practice is that they can communicate directly with the people who make decisions about the business.
Who it should be depends on size. In a small business, it can be the owner or operator. In a large business, FINTRAC expects someone from a senior level with direct access to senior management and the board.
Your three options
1. Appoint the owner or an existing manager
Common in small businesses. It works when that person has the time and the knowledge. The risk is that compliance competes with everything else they do.
2. Hire an in-house compliance officer
Right for larger or fast-growing businesses with steady volumes. You get full-time attention, at the cost of a senior salary and the challenge of finding someone experienced with Canadian requirements.
3. Use an outsourced compliance officer
An experienced compliance professional carries the day-to-day work, or supports the person you appoint, for the hours you need. However it's arranged, your business remains responsible for its obligations, and the arrangement should be set out in writing so it's clear who decides and signs off on what.
Side by side
| In-house hire | Outsourced | |
|---|---|---|
| Cost | A full-time senior salary | The hours you need; with us, US$1,500 per 10 hours |
| Experience | Depends on who you can hire | Someone who works with FINTRAC requirements every day |
| Scaling | Hire more people | Add hours as volumes grow |
| Best for | Large, steady operations | New, growing and foreign businesses |
What the work involves
Whichever option you choose, the work is the same: second-line review of customer onboarding, advice on cases and products, reporting to FINTRAC on time, keeping policies and the risk assessment current, client risk ratings, training, and preparing for the effectiveness review and any examination.
How to choose
- If no one in the business has AML experience, outsourcing gets you expertise straight away.
- If you're based outside Canada, a compliance officer who works with Canadian requirements daily closes a big gap.
- If volumes are high and steady, an in-house hire, supported by outside reviews, may make sense.
- Many businesses start outsourced and move in-house as they grow.
Sources: FINTRAC, Compliance program requirements. Checked 11 October 2026. General information, not legal advice.