Your Global MSB Licensing & Compliance Partner
Your Global MSB Licensing & Compliance Partner
Every FINTRAC-registered MSB must appoint a compliance officer. Hiring one full-time is expensive, and finding the right person takes months. Our fractional MLRO service gives your Canadian MSB or PSP an experienced compliance officer on a part-time basis, for a fraction of what an in-house hire costs.
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MLRO (Money Laundering Reporting Officer) is the international name for the role FINTRAC calls the compliance officer. Under the PCMLTFA, every money services business operating in Canada has to appoint someone to run its compliance program day to day. That person needs the knowledge, the authority and the time to actually do the job. Regulators look at this role first, and if the officer exists only on paper, the whole program is treated as deficient.
You have registered (or bought) an MSB but nobody on the team has AML experience or the time to run the program properly.
FINTRAC has announced an examination and you need an experienced officer to prepare responses, documentation and remediation quickly.
Your designated officer has left and the seat cannot stay empty. Continuity of the role is itself a regulatory requirement.
You are registering a new MSB or PSP and need a credible designated officer named in the application from day one.
We look at your business model, volumes and current program so we can size the engagement honestly.
You get a clear engagement letter covering scope, hours, deliverables and pricing. No surprises.
The officer is formally designated, then reviews the program and fixes what needs fixing.
Monitoring, reporting, training and regulator contact run on a steady monthly rhythm.
| Fractional MLRO | Full-time hire | |
|---|---|---|
| Typical annual cost | A fraction of a full-time salary | CAD 90k–150k+ plus benefits |
| Time to start | Days | 2–4 months recruiting |
| Experience level | Senior, multi-client exam experience | Depends on a single hire |
| Cover & continuity | Backed by a team | Single point of failure |
| Best for | Startups & small/mid MSBs | Large, high-volume operations |
The PCMLTFA does not describe the compliance officer in much detail, but examination practice does. These are the things an examiner will look for, and the things we make sure are genuinely in place.
The officer must be able to escalate, block a transaction and report to senior management without needing permission from the people whose work they are reviewing. We document this in the appointment letter so it is provable.
Canadian obligations have moved quickly since Bill C-12. An officer who was trained three years ago and has not kept up is a finding waiting to happen. Our officers work across multiple MSBs and see examination practice as it changes.
The most common failure we see is a founder or operations lead named as officer who simply has no hours in the week for it. A fractional officer has contracted hours that belong to compliance and nothing else.
Reviews, escalations, training sessions and reports all need a paper trail. If it is not written down, in an examination it did not happen. We keep the record as we go rather than reconstructing it later.
An officer whose pay depends on volumes approved has a conflict. An external officer does not carry that pressure, which is one of the quieter reasons regulators are comfortable with the model.
If the officer disappears, the obligation does not. Our engagements are backed by a team, so illness, leave or a handover never leaves the seat empty.
Most of the value in a fractional MLRO engagement lands early, when the programme is brought up to standard. Here is how that usually unfolds.
Designation is completed and filed. We review the existing programme, risk assessment and reporting history, and produce a written gap list ranked by regulatory exposure.
The highest-risk gaps get closed first. That is usually the risk assessment, the reporting procedures and any overdue STR or LCTR filings.
Training is delivered to staff and recorded. Monitoring thresholds are reviewed against actual transaction data rather than assumptions.
The programme moves into steady state: monthly reviews, a management report, and a schedule for the independent effectiveness review.
These come up again and again with Canadian MSBs, and every one of them is straightforward to correct once someone owns the role.
We do not publish a single figure because the honest answer depends on your volumes and risk profile. What we can be clear about is how the pricing is built.
| Engagement type | Typical profile | What drives the fee |
|---|---|---|
| Startup MSB | Pre-launch or first year, low volumes | Programme build effort, then light monthly oversight |
| Established MSB | Steady volumes, existing programme | Monitoring hours, reporting volume, staff numbers |
| Remediation | Post-examination findings | Scale of findings and the deadline you are working to |
| Urgent cover | Officer departed, exam announced | Speed of designation and the state of the existing programme |
Every engagement starts with a free scoping call and a written engagement letter. You will know the scope, the hours and the fee before anything begins.
