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Canada’s AML rules require businesses to use a risk-based approach (RBA) to fight financial crime. This means companies must identify their money laundering risks and put the right controls in place. A strong RBA helps businesses follow FINTRAC rules, improve efficiency, and reduce risks.

This guide explains the key steps for Canadian businesses to apply a risk-based approach to AML compliance in 2025.

1.A Deeper Understanding: Risk-Based Method for AML Compliance

A risk-based approach means businesses must:

• Recognize and evaluate risks tied to customers, transactions, and operations.
  

• Develop proportionate controls based on risk levels.
  
• Monitor and adjust compliance programs as risks evolve.
  

2. Key Steps to Implement an Effective RBA

a) Perform an AML Risk Assessment

Businesses need to assess their risk of money laundering (ML) and terrorist financing (TF) by considering:

• Customer profiles and transaction patterns.
  
• Geographic risk exposure.
  
• Product and service vulnerabilities.
  

Need help structuring your risk assessment? Our Consultation Services provide expert guidance.

b) Create Risk-Based Customer Due Diligence (CDD)

CDD should match the level of risk:

• Standard CDD for low-risk clients.
  
• Extra thorough checks (EDD) for high-risk customers.
  
• Continuous monitoring for suspicious transactions.

c) Strengthen Transaction Monitoring & Reporting

A risk-based AML program should include:

• Automated transaction monitoring for unusual activities.
  
• Suspicious Transaction Reports (STRs) submission to FINTRAC.
  
• Regular internal audits to assess program effectiveness.
  

Stay updated on AML reporting obligations to avoid non-compliance.

d) Implement Staff Training & Compliance Culture

AML compliance should be embedded into an organization’s culture through:

• Regular AML training programs for employees.
  
• A compliance officer responsible for regulatory adherence.
  
• Clear policies on reporting suspicious activities.
  

3. Common Challenges and Ways to Solve Them

a) Keeping Up with Changing Regulations

AML rules in Canada are always changing. Businesses should frequently check FINTRAC guidelines to stay compliant. (FINTRAC Updates)

b) Managing High Compliance Costs

Small businesses often struggle with the costs of AML compliance. Investing in automated compliance solutions can reduce overhead while ensuring regulatory adherence.

c) Balancing Customer Experience & Compliance

Excessive due diligence requirements can impact customer onboarding. Implementing risk-tiered onboarding processes helps maintain compliance while reducing friction for low-risk customers.

Final Thoughts

A risk-based approach to AML compliance is essential for Canadian businesses to meet FINTRAC regulations, mitigate financial crime risks, and operate efficiently. By assessing risks, enhancing due diligence, and leveraging compliance technology, businesses can stay ahead of regulatory challenges.

Need expert support with AML compliance? PayCompliance offers tailored solutions to help Canadian businesses navigate complex AML requirements.

Sources

• Financial Transactions and Reports Analysis Centre of Canada (FINTRAC): https://www.fintrac-canafe.gc.ca/
  
• Canadian AML Regulations: https://laws-lois.justice.gc.ca/eng/acts/P-24.501/
  
• FATF Guidelines on Risk-Based Approach: https://www.fatf-gafi.org/