1. Program Governance & Accountability
FINTRAC expects AML compliance to be actively managed—not simply assigned.
Governance failures often occur when responsibilities are unclear or when operational teams apply requirements differently.
Reflection Questions
- Could staff explain who owns AML compliance decisions?
- Do our written procedures match what employees actually do?
- Are exceptions tracked and approved consistently?
- How often are AML responsibilities reviewed and updated?
Strong Programs Typically
✓ Have documented ownership and escalation paths
✓ Maintain governance meeting records
✓ Review AML programs whenever operations change
Warning Signs
 Different teams follow different onboarding procedures
 Compliance responsibilities depend on institutional knowledge
 Policies have not been updated following business changes