What AML Leaders Are Talking About in 2025: Key Insights from the Toronto Conference

The recent AML conference in Toronto brought together compliance professionals, regulators, and law enforcement agencies to discuss the evolving landscape of financial crime prevention in Canada. For those who couldn't attend, the insights shared represent a significant shift in how FINTRAC is approaching compliance—and why your organization needs to be prepared.

FINTRAC's Enforcement Shift: From Assessment to Evaluation

The most critical takeaway from the conference came from AML consultants at firms like Outlier and MNP who work closely with FINTRAC's evaluation process. The regulatory landscape is changing dramatically: assessments can now quickly escalate into formal evaluations, and FINTRAC is taking a noticeably more aggressive enforcement stance.

This isn't just theoretical concern. Consultants with direct experience in the evaluation process confirmed that FINTRAC has moved into what industry insiders are calling "enforcement mode." For organizations that haven't kept pace with compliance requirements, this shift means greater scrutiny, higher stakes, and potentially significant penalties.

The message is clear: having your compliance infrastructure properly set up isn't optional anymore—it's essential for survival in this new regulatory environment.

The conference took place on September 11th, a date that holds profound significance for the financial crime prevention community. It's a sobering reminder of why this work matters beyond regulatory checkboxes and compliance reports.

The 9/11 attacks, which cost approximately $400,000 to execute, demonstrated how relatively small amounts of money moving through the financial system can enable catastrophic harm. The terrorists behind the attacks used bank accounts in the United States to fund their operation—transactions that, in hindsight, might have been detected with the sophisticated monitoring capabilities we have today.

This historical context isn't just about remembering a tragedy. It's about understanding the critical role that reporting entities play in national security. When you detect and report suspicious activities, you're providing law enforcement with intelligence that can prevent terrorism, combat organized crime, and protect vulnerable individuals from financial exploitation.

Your STR (Suspicious Transaction Report) isn't just a compliance document—it's a potential tool for saving lives.

One of the most valuable aspects of the Toronto conference was the opportunity for information sharing among AML professionals. The challenges facing compliance officers at banks, MSBs, casinos, and real estate firms often overlap, and collaborative problem-solving creates better outcomes for everyone.

Industry veterans emphasized that the organizations most at risk are those operating in isolation—particularly smaller entities that haven't built relationships within the compliance community or attended industry events. Without these connections, they're unaware of:

• Emerging typologies and red flags
• FINTRAC's shifting priorities and enforcement patterns
• Best practices for handling complex compliance scenarios
• Technology solutions that can streamline reporting obligations

What This Means for Your Organization

If you weren't at the conference, here's what you need to do:

1. Review Your Compliance Infrastructure Now

Don't wait for an assessment letter from FINTRAC. Conduct an internal audit of your compliance program against FINTRAC's current expectations. Pay special attention to:

• Your risk assessment methodology
• Ongoing monitoring capabilities
• Training documentation
• Record-keeping practices

2. Prepare for Enforcement

The days of lenient first-time warnings are fading. Ensure your organization has:

• Clear policies and procedures that reflect current requirements
• Documented evidence of implementation
• Regular testing and validation of your AML program
• Senior management buy-in and accountability

3. Build Your Network

Connect with industry associations, attend compliance events, and develop relationships with peers facing similar challenges. The intelligence you gain from these connections is invaluable.

4. Consider Expert Support

If your organization lacks internal expertise, engage with consultants who understand FINTRAC's expectations and can help you avoid the pitfalls that trigger evaluations.

The Bottom Line

The AML landscape in Canada is evolving rapidly, and FINTRAC's enforcement posture reflects the serious threats our financial system faces. Whether you're a compliance officer at a major bank or managing AML obligations for a small MSB, the stakes have never been higher.

But remember: behind every compliance requirement is a human story. The work we do to detect and prevent financial crime has real-world impact, protecting communities from terrorism, organized crime, and exploitation.

As we move through 2025, regulatory preparedness isn't just about avoiding penalties—it's about fulfilling our collective responsibility to safeguard the integrity of Canada's financial system.