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Mandatory Two-Year Effectiveness Review

Two Layers. One Examination.
Know Where You Stand.

FINTRAC examines both your compliance program and how it was executed at the transaction level. This diagnostic tests both — and shows exactly where FineProof™ operates and where your brokerage carries the responsibility.

FineProof™ governs the Program Layer
Your brokerage owns the Transaction Layer
Two layers. One examination.

FINTRAC does not examine the program in isolation. They test whether your compliance program was actually implemented in the field. Both layers must be examination-ready — but they carry different ownership.

Program Layer
Compliance governance — policy, structure, training, review
FineProof™ owns this
Governance
20%
Risk Assessment
20%
Policies & Procedures
25%
Training
15%
Effectiveness Review
20%
Program defines execution — FINTRAC tests both
A strong program with weak execution fails. Execution without a program is indefensible.
Transaction Layer
Client execution — KYC, EDD, risk scoring, reporting, records
Your brokerage owns this
KYC & Identification
20%
PEP / HIO
15%
Client Risk
15%
EDD
15%
Reporting
20%
Record Keeping
15%
FineProof™ governs this
Policy creation, review, and version control
Compliance Officer appointment and authority
Structured risk assessment lifecycle
Training delivery, tracking, and attestation
Two-year effectiveness review
ProofPack — examination-ready documentation
Your brokerage executes this
Client identity verification at transaction level
PEP/HIO screening and ongoing monitoring
Client risk scoring and EDD documentation
STR assessment and filing decisions
LCTR and LPEPR reporting obligations
Transaction and client record retention
What FINTRAC actually tests on examination day
An examiner will review your program documents and pull transaction files to test whether those documents were followed in practice. A brokerage with a structured program but inconsistent transaction execution will still receive findings. Both layers must be ready.
44 questions across both layers · Approximately 3–5 minutes · No document upload required
Full Compliance Diagnostic
Answer every question for your complete two-layer assessment
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Program Readiness
FineProof™
0%
Program
Deficient
Transaction Readiness
Brokerage
0%
Transaction
High Exposure
Failure Signals
Answer questions to see signals
Diagnostic Insight
Complete sections to generate your insight
Your Compliance Assessment

Your Two-Layer Diagnostic

Insight
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FineProof™ Scope
Program Readiness Score
0%
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How well your compliance program is structured and governed
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Brokerage Responsibility
Examination Exposure Score
0%
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What FINTRAC will probe at the transaction level
Understand the examination
Score Breakdown by Pillar
Next Step

Strengthen Your Compliance Framework

Focus on the part that determines examination outcomes. A structured program is the foundation everything else depends on.

Strengthen Your Compliance Framework
Focus on the part that determines examination outcomes.
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