Outlier Compliance Group

09/01/2026

FINTRAC has moved to an enforcement posture, and the compliance programs that were built around the old corrective action model need to be reassessed.

In this week's Weekly Cup of Compliance, Dr. Amber D. Scott explains how the penalty landscape has changed, where penalties are now being triggered, and why even a first examination is no longer a safe starting point for addressing gaps.

Self-reporting tools, follow-up meetings, information demands, and unregistered MSB status can all now result in direct penalties. The formal examination is no longer the only path to a fine.

Regulators expect compliance from day one. The enforcement posture reflects that expectation.

☕ Catch this week's Weekly Cup of Compliance below.

08/25/2026

Not all virtual assets are treated the same under Canadian law. Knowing the difference matters.

Rodney walks through the regulatory landscape for cryptocurrency in Canada and the distinction that trips up a lot of businesses: which assets are securities and which are not.

Bitcoin and Ethereum have been publicly confirmed as non-securities. Stablecoins are generally understood to be securities. Everything else? There are over 20,000 virtual assets and no official list to tell you where each one falls.

That ambiguity is exactly why expert guidance is not optional in this space.

☕ Catch this week's Weekly Cup of Compliance below.

08/18/2026

Before your firm starts using AI in its compliance program, there is one question worth answering: do you have a policy that governs it?

David walks through what responsible AI integration looks like in practice, starting with the foundational step most firms overlook and covering what compliance officers need to understand about the tools they are using.

AI is doing useful work right now in transaction monitoring and reporting. But replicable results and human oversight are not optional extras. They are what make AI defensible in a regulatory context.

AI is a powerful tool. It is not the compliance officer.

☕ Catch this week's Weekly Cup of Compliance below.

08/13/2026

Real estate brokerages in Canada paid more than $1 million in FINTRAC penalties over the past two years - an average of $80,148 each.

The pattern is almost always the same: AML obligations get pushed aside all year, then everything gets fixed in a panic once FINTRAC makes contact. The problem is that FINTRAC is reviewing whether you had a working program during that period, not whether you built one afterward.

Our new post covers the baseline obligations every brokerage needs, why the two-year effectiveness review should be your starting point, and the difference between a high-risk transaction, a suspicious one, and a deal you legally can't touch.

Read it here: https://www.outliercanada.com/your-real-estate-business-cant-afford-just-in-time-compliance/

13 Canadian brokerages paid over $1M in FINTRAC penalties in two years. Why just-in-time AML compliance fails — and what to fix first.

08/11/2026

Your business-wide risk assessment tells you about your firm. Your relationship-based risk assessment tells you about your customers. You need both.

Daniel Dobre walks through what a relationship-based risk assessment actually involves and the four factors that have to be evaluated every time a new business relationship is established.

Where is the customer located? What services are they using? What does their activity look like? These are not optional questions. They are the foundation of understanding what risk a specific customer brings through the door.

One assessment does not cover everything. That is kind of the point.

☕ Catch this week's Weekly Cup of Compliance below.

08/04/2026

Canada's AML regime has improved in meaningful ways over recent years. But some of the same issues are expected to show up in our FATF evaluation, and they are not minor ones.

In this week's Weekly Cup of Compliance, David Vijan and Amber Scott discuss the gaps that are expected to generate repeat findings in future evaluations, including beneficial ownership, sanctions, and the long-standing challenge of bringing the legal sector into the AML framework in a meaningful way.

Sophisticated money laundering schemes frequently rely on complicit lawyers or accountants. As long as that sector sits outside meaningful AML legislation, Canada's FATF standing will reflect it.

Some gaps are technical. This one is structural.

☕ Catch this week's Weekly Cup of Compliance below.

07/29/2026

FINTRAC examinations in the real estate sector are increasing, and the firms most at risk are the ones treating compliance as a reactive task.

In this week's Weekly Cup of Compliance, Rodney MacInnes explains just on time compliance, what it looks like in practice, and why it is no longer a viable approach under the current penalty regime.

Scrambling after an exam is announced does not produce the documented history FINTRAC is looking for. And with penalties now capable of reaching 40 times their previous amounts, the financial exposure from a failed exam has changed entirely.

A compliance program left on a shelf is not a compliance program. It is a liability.

☕ Catch this week's Weekly Cup of Compliance below.

07/21/2026

"We have transaction monitoring in place and the parameters are in our IT system." Sounds reasonable. Regulators will not think so.

Outlier's David Vijan breaks down why vague compliance documentation is one of the most common issues in maturing organizations and what actually needs to be on the page.

How often does monitoring run? How are alerts worked? What are the exact steps from alert to investigation to STR? If your compliance manual cannot answer those questions, it is not detailed enough.

Business processes evolve. Compliance documentation needs to keep up.

☕ Catch this week's Weekly Cup of Compliance below.

07/14/2026

AI in compliance tools can raise real questions about transparency and regulatory acceptance. But for sanctions screening specifically, the picture is clearer than most firms realize.

In this week's Weekly Cup of Compliance, Daniel Dobre explains why AI-driven screening is acceptable from a regulatory standpoint, provided the system is generating accurate alerts.

The initial screening function is a data comparison exercise. AI handles that the same way traditional technology does. The concern is not how the match was identified. It is whether the alert was created at all.

The more complex question is what role AI should play in investigating those alerts after the fact. That discussion is still evolving.

☕ Catch this week's Weekly Cup of Compliance below.

07/09/2026

Big congratulations to Maria Shamou on her promotion to AML Project Coordinator! 🎉

Maria has been an invaluable member of the Outlier team, and in her new role she'll be coordinating our AML projects to ensure seamless delivery for our clients.

Her hard work and dedication have truly earned this. Join us in celebrating Maria! 👏