We Design, Build, and Test Regulator-Ready Compliance Programs — So You Can Lead with Clarity and Confidence.
FRACTIONAL COMPLIANCE LEADERSHIP
Fractional Compliance Support for Regulated Financial Firms.
Many growing financial firms reach a point where regulatory obligations outpace internal capacity. A senior leader is often required to assume the Chief Compliance Officer (CCO) or Chief Anti-Money Laundering Officer (CAMLO) function alongside their primary role.We provide fractional, behind-the-scenes compliance support to design, implement and strengthen programs aligned with regulatory expectations — and capable of standing up to regulatory scrutiny.
Who We Serve
Designed for firms operating under pressure.
This service is designed for regulated financial firms where compliance demands have outpaced what internal teams can reasonably absorb.
Senior leaders acting as CCO or CAMLO alongside primary responsibilities
Compliance obligations exceeding internal capacity or resources
Firms preparing for or undergoing FINTRAC effectiveness reviews
Firms subject to regulatory examinations (e.g. OSC, OSFI, FINTRAC etc.)
Firms subject to regulatory terms & conditions imposed by a securities regulator
HOW WE SUPPORT YOU
Two core functions. One regulator-ready outcome.
Our services ensure your compliance program is not only well-designed, but capable of standing up to regulatory examination.
01 · Advisory Services
Build and Operate
We design, implement and maintain compliance programs tailored to the firm’s business model, risk profile and regulatory obligations.
02 · Quality Assurance
Test & Validate
We independently assess whether compliance programs are appropriately designed and test to confirm they are operating effectively in practice.
Services Snapshot
A focused capability set.
Advisory
Fractional Chief Compliance Officer (CCO) or Chief Anti-Money Laundering Officer (CAMLO) support services
Compliance program design and enhancement
AML frameworks and risk assessment methodologies
Operational compliance support
Project management (e.g. implementation of new compliance software or solutions)
Regulatory registrations and filings
Compliance training
Board and senior management reporting
Quality Assurance
FINTRAC effectiveness reviews
Compliance testing and file reviews
Mock Regulatory Examinations
industry focus
Sectors we know.
Portfolio Managers and Exempt Market Dealers (NI 31-103 Registrants)
Mortgage brokerages
Money services businesses (MSBs) including MSBs impacted by Ministerial Directive (Iran)
Crypto firms and exchanges
Provincially regulated firms (Credit unions, trust companies etc.)
OSFI-regulated entities
We bring direct experience working within these sectors, enabling practical, context-specific compliance support.
Track Record
Over Two decades of regulatory depth.
TrustPoint Compliance Advisors is built on over two decades of regulatory compliance, risk management and governance experience across Canadian and international financial services sectors.
25+ years in regulatory compliance, AML/ATF and risk management across banking, capital markets and asset management
Former Chief Compliance Officer roles within large and complex financial institutions
Designed and implemented enterprise compliance programs across multi-asset and regulated environments
Proven track record of programs that have withstood regulator scrutiny
Experience across multiple regulated sectors and jurisdictions
Time-Sensitive Matters
Some compliance deadlines do not wait.
FINTRAC Effectiveness Review Deadlines (Mortgage Brokers)
Mortgage brokers became subject to FINTRAC requirements on October 11, 2024. Many firms are now approaching their first mandatory effectiveness review cycle.For firms that have not yet:
Fully operationalized their AML program
Established a documented risk-based approach
Implemented monitoring, reporting and recordkeeping processes
Timeframes can become compressed as review deadlines approach. Early engagement allows firms to complete their effectiveness review in a structured and defensible manner.
Regulatory Terms & Conditions and Remediation Requirements
Some firms may be subject to terms and conditions imposed by a securities regulator, requiring:
Appointment of a Compliance Monitor and/or a qualified Chief Compliance Officer
Execution of a formal compliance plan
Independent oversight or compliance monitoring
These situations typically involve:
Defined timelines
Ongoing regulatory reporting
Expectations for demonstrable progress and evidence of remediation
Timely support is critical to ensure remediation activities are completed effectively and regulatory expectations are met.
Book a consultation to assess your compliance program — and identify gaps before regulators do.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
INTRO
Compliance support across two core functions.
(1) Advisory — building or enhancing, and operating your compliance program.(2) Quality Assurance — testing and validating effectiveness.
SERVICE 01
Advisory & Support Services
Fractional CCO / CAMLO Support (Temporary or Ongoing)Supporting appointed Chief Compliance Officers (CCOs) and Chief Anti-Money Laundering Officers (CAMLOs) with the day-to-day execution and ongoing oversight of the compliance program, including:
Program oversight and issue escalation support
Maintenance of policies, procedures and controls
Preparation of compliance reports to senior management and the board
Ongoing monitoring of regulatory developments and expectations
In appropriate circumstances:
Acting as CAMLO on a part-time or interim basis, where the role does not warrant a full-time position
In limited circumstances, acting as CCO of a securities registrant, subject to regulatory approval, capacity constraints and conflict of interest considerations
Compliance Program Design and EnhancementDevelopment and refinement of compliance frameworks tailored to the firm's business model, including:
Policies and procedures aligned with applicable regulatory requirements
Control design and documentation, including clearly defined control activities and supporting evidence
Governance structures and compliance frameworks, including:
Application of NI 31-103 compliance system requirements, including governance, policies and procedures, and ongoing monitoring
Development of AML/ATF programs consistent with FINTRAC requirements under applicable legislation, including risk assessments, policies and procedures, ongoing monitoring, reporting and training
Implementation of OSFI Guideline E-13 (Regulatory Compliance Management) principles, including compliance governance, risk identification, control frameworks and reporting to senior management and the board
Consideration of broader regulatory expectations and supervisory guidance, including securities regulators, FINTRAC and relevant industry practices
AML Risk Assessments and MethodologiesDesign and implementation of structured, risk-based AML/ATF frameworks tailored to the firm's business model and regulatory obligations, including:
Enterprise-level AML/ATF risk assessments, covering customer characteristics, products and services, delivery channels, geographic exposure and other relevant factors
Development of formal risk assessment methodologies, including clearly defined risk criteria, likelihood and consequence scoring, and documented risk evaluation processes
Customer risk rating frameworks, including scorecards to assess and document ML/TF risk at onboarding and throughout the business relationship
Automated risk scoring tools (e.g., Excel-based scorecards), where risk ratings are systematically computed based on responses to standardized inputs (e.g., drop-down selections), enabling:
Consistent and repeatable risk assessments across the firm
Reduced reliance on subjective judgment
Practical implementation for firms with limited systems or technology infrastructure
Identification and analysis of ML/TF risk typologies and behavioural patterns relevant to the firm's products, services and operating environment
AML/ATF risk registers, documenting identified risks, control effectiveness, residual risk and mitigation strategies
Design of risk mitigation strategies, including enhanced due diligence, escalation protocols and control enhancements
Integration of risk assessment outputs into operational processes, including KYC, monitoring, reporting and decision-making
Ongoing monitoring and periodic review frameworks, including trigger events and continuous refinement of the risk-based approach
Operational Compliance SupportPractical support to maintain the day-to-day operation of core compliance activities. This may involve a range of activities such as:
KYC and onboarding processes, including documentation standards, completeness checks and alignment with regulatory requirements
Trade and transaction reviews, including post-trade monitoring, exception identification and support for best execution and suitability oversight
Personal trading and conflicts of interest monitoring, including pre-clearance processes, restricted lists and periodic reviews
Transaction monitoring and alert management, including review, investigation and documentation of alerts and escalation where required
Ongoing monitoring and trigger event identification, including material changes in customer circumstances and risk profile updates
Sanctions, PEP and adverse media screening workflows, including escalation and documentation of potential matches
Escalation protocols and case documentation, including maintenance of audit-ready records and decision rationales
Support for regulatory reporting processes, including preparation and documentation of reports (e.g., STRs, EFTRs, LCTRs, internal logs)
This support is designed to embed compliance into daily operations — ensuring activities are performed consistently, documented appropriately, and capable of withstanding regulatory review.
Regulatory Registrations and FilingsSupport with regulatory filings and interactions, including:
Securities registration processes and NRD filings
FINTRAC registration and reporting obligations, including use of the FINTRAC Web Reporting System (FWR)
Coordination of responses to regulatory inquiries
Preparation of documentation to support regulatory submissions
Compliance Trainingevelopment and delivery of compliance training programs aligned with regulatory expectations, including:
Design of role-specific training programs, tailored to the firm's business model and regulatory obligations (e.g., NI 31-103, FINTRAC)
AML/ATF, sanctions and general compliance training, including onboarding and annual refresher programs
Implementation of structured, screen-based training solutions, using third-party platforms (e.g., LRN) or internally developed tools
Development of in-house training delivery frameworks, leveraging tools such as SharePoint and Microsoft Forms to distribute training materials and track the completion of knowledge assessments
Tracking and reporting of training completion, including maintenance of audit-ready records
Assessment of comprehension through quizzes and testing, with documented results to evidence understanding and effectiveness
SERVICE 02
Quality Assurance
Independent assessment of whether compliance programs are designed appropriately and operating effectively in practice.
FINTRAC Effectiveness Reviews (Mandatory AML Reviews)Independent reviews of AML/ATF compliance programs as required under the PCMLTFA, including:
Assessment of the firm's risk-based approach
Review of policies, procedures and controls
Testing of monitoring, reporting and recordkeeping processes
Sample-based file and transaction testing
Identification of gaps and control weaknesses
Delivery of a written report with findings and remediation recommendations
Compliance Monitor & Regulatory Remediation SupportSupport for firms subject to regulatory oversight or remedial requirements, including:
serving as a compliance monitor pursuant to terms and conditions imposed by a securities regulator
Independent oversight and reporting on remediation activities
Assessment of progress against regulatory requirements and commitments
Support in responding to regulatory findings, deficiency letters and examination reports
Development and validation of remediation plans
Compliance Testing and File ReviewsTargeted testing of key compliance controls and activities, including:
KYC and onboarding file reviews
Transaction monitoring and alert reviews
Trade reviews and suitability oversight (for NI 31-103 registrants)
Personal trading and conflicts of interest monitoring
Sanctions, PEP and adverse media screening processes
Assessment of documentation quality and audit readiness
Mock Regulatory ExaminationsPreparation for FINTRAC and securities regulator reviews, including:
Simulated regulatory examinations based on current supervisory focus areas
Review of policies, procedures, files and supporting documentation
Identification of deficiencies and areas of regulatory risk
Preparation of management for regulator interaction and inquiries
Compliance Technology Implementation & Project ManagementSupport for the selection, implementation and operational integration of compliance-related systems and tools, ensuring alignment with regulatory requirements and the firm's business model. This support may involve:
Project management of compliance technology initiatives, including planning, timelines, stakeholder coordination and vendor oversight
Assessment and selection of compliance tools, including KYC platforms, sanctions/PEP screening solutions, transaction monitoring systems and case management tools
Translation of regulatory requirements into system design, ensuring tools are configured to support compliance obligations
Configuration support and workflow design, including onboarding processes, monitoring triggers, escalation pathways and documentation standards
Integration of systems into existing operations, ensuring alignment with front-line processes and minimizing operational disruption
Testing and validation of system outputs, including ensuring data integrity, accuracy of alerts and adequacy of audit trails
Development of supporting policies, procedures and user guidance, aligned with system functionality
Post-implementation review and optimization, including identification of gaps and enhancements
These services provide independent validation that compliance programs are not only documented, but operating effectively and capable of withstanding regulatory scrutiny.
SERVICE 03
Independent AML Reviews for Canadian Reporting Entities
Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), reporting entities are required to conduct an independent effectiveness review of their AML/ATF program at least every two years.These reviews assess whether your compliance program is not only documented, but operating effectively in practice and aligned with FINTRAC expectations.
Sector-Specific Experience That MattersWe conduct effectiveness reviews with a practical understanding of how AML programs operate within specific sectors, including:
Mortgage brokerages
Money services businesses (MSBs)
Crypto firms
Securities registrants
Credit unions
Smaller OSFI regulated banks
This experience allows us to:
Assess your program in the context of your actual business model and workflows
Identify risks and gaps that are specific to your sector
Apply real-world regulatory expectations, not generic checklists
Our ApproachOur reviews go beyond documentation and assess how your program functions in practice, including:
Validation of your risk assessment methodology
Review of policies, procedures and controls, including alignment with current FINTRAC guidance
Assessment of monitoring, reporting and recordkeeping processes, including transaction monitoring and escalation practices
Sample-based testing of files and transactions, including KYC, screening, and reporting decisions
Evaluation of training, governance and oversight, including evidence of implementation
Deliverables
Independent written report documenting scope, methodology and findings
Clear identification of deficiencies and control gaps
Practical, prioritized remediation roadmap tailored to your business
Supporting documentation designed to be audit-ready for FINTRAC examination
When to Engage
You are approaching your 2-year FINTRAC effectiveness review requirement
You have not previously conducted a formal review
You want to assess your program before a FINTRAC examination
Your business has experienced growth or changes in products, channels or customer base
Why TrustPoint
Experience designing and testing AML programs across multiple regulated sectors
Familiarity with FINTRAC examination expectations and common deficiencies
Practical, risk-based approach focused on how programs operate in reality
Reviews designed to be defensible, documented and regulator-ready
Many firms have policies and procedures in place — but limited evidence that they are being applied consistently in practice or that compliance with those policies is effectively demonstrated. This is a common focus area in FINTRAC examinations.
Book a consultation to assess your compliance program — and identify gaps before regulators do.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
INDUSTRIES
Industries We Support
We support a range of regulated financial service providers in Canada, with a focus on firms where compliance responsibilities must be executed with limited internal resources.
Our approach is tailored to each sector's regulatory framework, operating model and risk profile, ensuring compliance programs are both practical and defensible under regulatory scrutiny.
NI 31-103 Registrants (Portfolio Managers & Exempt Market Dealers)
Support aligned with securities regulatory requirements and the practical operation of compliance systems, including:
KYC, KYP and suitability processes, including account opening documentation, ongoing monitoring and support for reassessments
Compliance systems, including development and maintenance of policies, procedures, controls and supervision frameworks
Trade supervision and best execution oversight, including periodic evaluation of execution quality and documentation of key factors (price, speed, liquidity and cost)
Fair allocation and conflict of interest management, including allocation methodologies, restricted lists and conflict identification and escalation
Personal trading monitoring, including pre-clearance processes, trade reviews and recordkeeping
Books and records management, ensuring records are complete, accurate and can be produced to regulators in a timely manner
Client reporting and disclosure controls, including review of performance reporting, charges and compensation disclosures, and supporting documentation
Portfolio reconciliation and account oversight, including reconciliation of portfolio records to custodian statements and review of client account statements
Marketing review and approval processes, including compliance review, documentation and controls to prevent misleading or unsupported claims
Monitoring of investment limits and exemption requirements, including documentation to support compliance with offering memorandum and other exemptions
Preparation for regulatory examinations and remediation support, including addressing deficiencies, strengthening controls and enhancing documentation
Money Services Businesses (MSBs) & Crypto Platforms
Support for high-risk, transaction-driven businesses with elevated regulatory expectations, including:
FINTRAC registration and ongoing compliance requirements
Transaction monitoring and alert management frameworks, including investigation and escalation protocols
AML/ATF risk assessments, including geographic and product risk exposure
Reporting obligations, including STRs, EFTRs, LCTRs and recordkeeping requirements
Sanctions compliance and exposure management, including screening and escalation workflows
Preparation for FINTRAC examinations and effectiveness reviews
Credit Unions & OSFI-Regulated Entities
Support aligned with enterprise-level compliance and governance expectations, including:
Implementation of compliance frameworks aligned with OSFI Guideline E-13 (Regulatory Compliance Management)
Compliance governance and oversight structures, including board and senior management reporting
Risk identification and control frameworks, including documentation and testing
Integration of compliance into enterprise risk management (ERM)
Independent testing and quality assurance of compliance programs
Support for internal reviews, audits and regulatory examinations
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
USE CASES
Notable experience and engagements.
Representative examples of how we have built, remediated and tested compliance programs across regulated sectors in Canada and abroad.Explore our experience by sector or engagement type:
Mortgage Brokerage AML Program Build & FINTRAC Readiness
OSC Terms & Conditions Remediation and CCO Engagement
AML Program Enhancement for a High-Risk MSB (Iran-Linked EFT Activity)
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
USE CASE 01
Building an AML Program for a Mortgage Brokerage
Client ContextA large mortgage brokerage became subject to FINTRAC requirements following the expansion of the PCMLTFA to the sector in October 2024.At the outset, the firm relied on high-level, franchisor-provided AML materials that:
Did not clearly assign responsibilities
Lacked operational guidance for brokers
Did not address corporate borrowers or beneficial ownership
Provided limited support for documenting and evidencing compliance
As a result, the firm faced challenges demonstrating that its AML program was operating effectively in practice.
Our RoleWe were engaged to design and implement a fully operational, risk-based AML/ATF program, aligned with FINTRAC's expectations for effectiveness.
What We Delivered
1. End-to-End AML FrameworkConsistent and repeatable risk assessments across the firm
Developed a custom Policies & Procedures Manual (PPM) tailored to the firm's actual workflows
Embedded step-by-step operational guidance, including system screenshots and documentation standards
Introduced structured processes for:
KYC and source of funds verification
Corporate onboarding and beneficial ownership
Third-party determination and PEP handling
2. Risk-Based Approach (RBA) and Risk RegistersDesigned a comprehensive AML risk assessment framework, covering:
Customer, product, geographic and channel risks
ML/TF and sanctions exposure
Implemented:
ML/TF & Sanctions Risk Register
Regulatory Compliance Risk Register
These tools linked identified risks directly to controls and mitigation measures, making the program defensible and auditable.
3. Customer Risk Scorecard (Operationalization of AML Risk)
Built a standardized, weighted risk scorecard applied at the file level
Enabled brokers to assess risk through structured inputs (e.g., borrower profile, mortgage product type, property and transaction attributes, geography)
Automatically generated consistent risk ratings, reducing subjectivity
For higher-risk files:
Triggered enhanced due diligence (EDD)
Required escalation to the AML Officer
Ensured decisions were documented and auditable
4. Governance and Oversight FrameworkEstablished a formal AML governance structure, including:
Appointment of a dedicated AML Officer
Direct reporting to senior management
Weekly compliance oversight meetings
Implemented structured:
Issue escalation
Policy updates
Risk reporting
5. Training and Compliance Culture
Implemented a structured training program using the LRN platform
Developed:
Role-specific training aligned with the PPM
Comprehension testing and completion tracking
Introduced:
Live training sessions
Ongoing awareness communications
This ensured training was trackable, consistent and auditable.
6. Monitoring, QA and Issue Management
Introduced:
First-line controls (broker documentation standards)
Second-line QA reviews to identify deficiencies
Established an Issue Management Log to track:
Deficiencies
Remediation actions
Recurring themes and risks
Developed a roadmap to evolve QA from checklist-based review to a risk-sensitive oversight function
7. Addressing System LimitationsThe firm's core system presented significant limitations, including:
No enterprise-level reporting capability
Weak sanctions screening functionality
No alert or case management tools
To address this:
Designed manual compensating controls and workflows
Implemented external screening processes
Engaged with the system provider to advocate for enhancements
Outcome
Transitioned from generic, high-level documentation to a fully operational AML program
Established a risk-based, auditable framework aligned with FINTRAC expectations
Enabled consistent application of:
Risk assessments
Documentation standards
Escalation protocols
Positioned the firm to:
Demonstrate program effectiveness
Prepare for FINTRAC examination
Support ongoing compliance as the sector matures
KEY INSIGHT
Many firms have policies in place — but lack the structure, tools and documentation to demonstrate that those policies are being applied consistently in practice.This engagement focused on bridging that gap — turning a documented program into one that is operational, testable and defensible.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
USE CASE 02
Regulatory Remediation and Removal of Terms & Conditions
Client ContextA securities registrant was subject to terms and conditions imposed by a securities regulator, requiring the firm to:
Appoint a qualified Chief Compliance Officer (CCO)
Implement a formal compliance plan to address identified deficiencies
Operate under the oversight of a compliance monitor
The firm required immediate support to stabilize its compliance function, address regulatory expectations and execute a structured remediation plan.
Our RoleWe were engaged to:
Serve as the firm's CCO
Support the execution of a comprehensive compliance remediation plan
Provide independent compliance oversight and testing aligned with regulatory expectations
What We Delivered
1. Stabilization of the Compliance Function
Assumed responsibility for CCO oversight and reporting
Established clear governance, escalation and supervision frameworks
Implemented structured compliance monitoring and issue tracking processes
2. Execution of the Compliance Plan
Reviewed and prioritized all regulatory findings and deficiencies
Developed and implemented a detailed remediation roadmap
Enhanced key components of the compliance program, including:
Policies and procedures
KYC, suitability and documentation practices
Conflicts of interest identification and management
Books and records controls
3. Regulatory Engagement and Reporting
Supported the firm in responding to regulatory requirements and inquiries
Provided structured progress reporting on remediation activities
Ensured documentation and outputs were aligned with regulatory expectations
Outcome
Successfully implemented the firm's compliance remediation plan
Established a functional and sustainable compliance framework
Demonstrated that controls were:
Clearly defined
Consistently applied
Operating effectively
As a result: The terms and conditions imposed by the securities regulator were lifted.
KEY INSIGHT
Regulatory remediation is not achieved through documentation alone — it requires structured execution, testing and evidence that controls are operating effectively in practice.This engagement focused on restoring a compliance function that was not only aligned with regulatory requirements, but capable of demonstrating that alignment under scrutiny.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
USE CASE 03
AML Program Enhancement for High-Risk MSB (Iran-Linked EFT Activity)
Client ContextA Canadian Money Services Business (MSB) specializing in foreign exchange and remittance services facilitated high volumes of electronic funds transfers (EFTs) with a nexus to Iran.Under the PCMLTFA and applicable Ministerial Directives:
All transactions associated with Iran were required to be treated as high risk
Enhanced due diligence, monitoring and reporting obligations applied
Regulatory expectations extended beyond documentation to demonstrable program effectiveness
The business operated in a complex and resource-intensive environment, including:
High transaction volumes
Ongoing FINTRAC examination and audit activity
Significant interpretive challenges relating to reporting obligations
Our RoleWe were engaged to:
Serve as Chief Anti-Money Laundering Officer (CAMLO)
Strengthen the firm's AML/ATF compliance framework
Enhance monitoring, reporting and control effectiveness
Support regulatory interpretation and engagement with FINTRAC
Foster trusted relationships with business partners and banking providers
What We Delivered
1.High-Risk Transaction Framework (Iran Nexus)
Formalized treatment of all Iran-linked transactions as high risk, consistent with Ministerial Directive requirements
Implemented controls to ensure:
Collection of source of funds and purpose for all relevant transactions
Consistent application of enhanced due diligence (EDD)
Clear documentation to support reporting decisions
Established processes to ensure:
EFT and large cash transaction reporting aligned with regulatory expectations
Appropriate use of STR reporting where suspicion thresholds were met
2. Transaction Monitoring & Rule-Based ControlsDesigned a comprehensive AML risk assessment framework, covering:
Designed and implemented rule-based monitoring within the core system (CurrencyXchanger / 4D), including:
Aggregation rules to identify high cumulative transaction values
Alerts for high transaction volume patterns
Detection of potential structuring (cash and EFT)
Triggers requiring compliance override and EDD documentation
Introduced a shift toward preventative controls, including:
Pre-trade restrictions
Mandatory data fields
Embedded compliance checks within workflows
3. Regulatory Interpretation & Engagement
Led formal interpretation requests to FINTRAC on complex reporting scenarios, including:
Treatment of domestic settlement transactions linked to Iran flows
Clarification of reporting obligations under the Ministerial Directiven
Incorporated FINTRAC guidance into:
Policies and procedures
Reporting practices
Staff guidance and escalation protocols
This ensured the program was aligned with current regulatory interpretation, not assumptions.
4. Governance and Compliance Oversight
Established a direct reporting line from CAMLO to the senior officers and directors of the company
Implemented structured:
Compliance reporting
Issue escalation
Monitoring of remediation activities
Provided guidance on:
Resourcing the compliance function
Balancing audit demands with operational priorities
5. Technology Enablement and Control Design
Leveraged and enhanced existing systems, including:
CRM-integrated AML module
Identity verification tools
Sanctions and adverse media screening solutions
Focused on:
Embedding controls directly into operational systems
Improving data capture, audit trails and documentation quality
Aligning system functionality with regulatory expectations for monitoring and reporting
Outcome
Established a structured, risk-based AML program tailored to a high-risk jurisdictional exposure
Implemented defensible transaction monitoring and reporting processes
Achieved alignment with FINTRAC expectations and interpretive guidance
Strengthened governance, documentation and audit readiness
Established a long-term trusting relationship with a key business partner
As a result, the firm was able to:
Operate high transaction volumes within a controlled and well-documented framework
Demonstrate that AML controls were:
Clearly defined
Consistently applied
Supported by sufficient evidence
Strengthen relationships with banking and payment service providers, who, following review of the enhanced compliance program, reduced their level of heightened scrutiny and oversight
KEY INSIGHT
High-risk jurisdictions do not preclude business activity — but they significantly elevate expectations around documentation, monitoring and evidence of compliance.This engagement focused on ensuring the firm could operate within that environment while maintaining a program that was defensible under regulatory scrutiny.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
USE CASE 04
Implementation of Automated Compliance Monitoring (Bloomberg & FundApps)
Client ContextAn investment management firm required the implementation of automated compliance monitoring tools to support:
Portfolio compliance with regulatory and client mandate restrictions
Pre- and post-trade controls
Monitoring of regulatory ownership thresholds and related filing obligations
The firm had selected Bloomberg AIM and FundApps, which incorporates regulatory rule sets designed to reflect applicable market requirements.The firm required support to ensure these systems were:
Properly configured and calibrated
Aligned with the firm's specific portfolios and structures
Embedded into day-to-day compliance processes
Our RoleWe were engaged to:
Lead the implementation and operationalization of compliance monitoring tools
Translate regulatory obligations and mandate requirements into practical system configurations and workflows
Ensure outputs were usable, reliable and supported by appropriate controls and documentation
What We Delivered
1. Configuration of Monitoring Rules and Thresholds
Implemented and calibrated monitoring rules within FundApps to track:
Regulatory ownership thresholds and disclosure triggers
Aggregated positions across accounts and strategies
Internal investment limits and client mandate restrictions
Ensured rules were:
Appropriately configured to reflect the firm's holdings and structures
Tested against real portfolio data
Supported by clear internal documentation
2. Regulatory Threshold Monitoring and Escalation
Established processes to support:
Identification of threshold breaches and near-breaches
Escalation to compliance for assessment of filing requirements
Documentation of decisions and supporting rationale
Integrated system alerts into a structured compliance workflow, ensuring:
Timely review of alerts
Consistent handling of regulatory triggers
Clear audit trails
3. Pre-Trade and Post-Trade Control Framework
Configured pre-trade controls within Bloomberg AIM to:
Prevent breaches of investment restrictions prior to execution
Flag exceptions requiring compliance review
Leveraged FundApps for post-trade monitoring to:
Identify potential breaches of thresholds and limits
Support ongoing compliance oversight
4. Alert Management and Operational Workflows
Designed and implemented processes for:
Alert triage and investigation
Coordination between compliance and portfolio management
Documentation of outcomes, including filing decisions where applicable
Ensured alerts were:
Actionable and prioritized
Incorporated into regular compliance monitoring activities
5. Data Integrity and Testing
Conducted testing to ensure:
Accuracy of position aggregation
Reliability of threshold monitoring
Consistency between system outputs and underlying data
Identified and resolved:
Data mapping and feed issues
Inconsistencies affecting alert accuracy
6. Data mapping and feed issues Inconsistencies affecting alert accuracy
Developed supporting:
Policies and procedures aligned with system functionality
Internal guidance for handling regulatory threshold alerts
Documentation supporting regulatory and audit review
Embedded monitoring processes into the firm's overall compliance framework
Outcome
Successfully implemented automated monitoring of investment restrictions and regulatory thresholds
Established a structured process for identifying, escalating and documenting potential filing obligations
Reduced reliance on manual tracking of ownership levels and limits
Improved consistency, timeliness and auditability of compliance processes
As a result, the firm was able to:
Demonstrate that compliance controls were systematic, repeatable and evidence-based
Reduce operational risk associated with missed or delayed regulatory filings
Support scalable growth while maintaining robust compliance oversight
KEY INSIGHT
Compliance technology does not eliminate regulatory risk — it requires proper configuration, testing and integration into workflows to produce reliable and defensible outcomes.This project focused on ensuring that system outputs were understood, actionable and supported by appropriate governance and documentation.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
INSIGHTS
Practical perspectives on Canadian compliance.
Articles on regulatory developments, emerging trends and the operational realities of running a compliance program.Forthcoming.
Need guidance on a specific regulatory requirement? Book a consultation.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
WHO WE ARE
About TrustPoint Compliance Advisors
TrustPoint Compliance Advisors supports Canadian financial service firms in designing, implementing and maintaining compliance programs aligned with regulatory expectations.
We work with firms where compliance responsibilities have outpaced internal capacity — including those where a senior leader is effectively "wearing two hats," acting as Chief Compliance Officer (CCO) or Chief Anti-Money Laundering Officer (CAMLO) alongside their primary responsibilities, often without dedicated support.Our focus is on practical implementation, not theoretical frameworks. We help firms build and operate compliance programs that are clearly defined, consistently applied and supported by sufficient evidence to withstand regulatory scrutiny.
Our Approach
Demonstrable in practice.
"A compliance program is only effective if it can be demonstrated in practice."We support firms across three core areas:
Advisory & Support — designing and operating compliance programs
Operational Support — assisting with day-to-day execution of compliance activities
Quality Assurance — independently testing whether programs are operating effectively
This approach ensures compliance programs are not only documented, but functional, sustainable and defensible.
Experience That Matters
Across regulated sectors.
Our work is informed by experience across a range of regulated financial sectors, including:
NI 31-103 registrants (portfolio managers and exempt market dealers)
Mortgage brokerages subject to FINTRAC requirements
Money services businesses and crypto firms
Credit unions and OSFI-regulated entities
We have direct experience designing, implementing and assessing compliance programs in environments subject to regulatory examination, remediation and ongoing oversight.
How We Work
Senior expertise. Right-sized engagements.
We provide fractional and project-based support, allowing firms to access senior compliance expertise without the need for a full-time hire.Our role is to support and strengthen the compliance function — not replace it — ensuring firms can meet regulatory expectations in a practical and proportionate manner.Our objective is to help firms establish compliance programs that work in practice — and can be clearly demonstrated when it matters most.
Founder & Principal
Daniel Speirs
TrustPoint Compliance Advisors
Daniel Speirs is a regulatory compliance professional with over 25 years of experience supporting financial service firms across multiple jurisdictions.He began his career in the Cayman Islands, working in offshore financial services and AML compliance, before relocating to Canada in 2007. Since then, Daniel has held senior compliance roles, including Chief Compliance Officer and Chief Anti-Money Laundering Officer, within Canadian banks, investment management firms and a large institutional asset manager.Daniel has extensive experience designing, implementing and enhancing compliance programs across a range of regulatory frameworks, including securities regulation, AML/ATF and prudential requirements. He has also supported firms operating under regulatory scrutiny, including those subject to remediation requirements, compliance plans and ongoing oversight.As a consultant, Daniel provides practical, hands-on support to portfolio managers, exempt market dealers, mortgage brokerages, money services businesses and crypto firms. His work focuses on building compliance programs that are not only aligned with regulatory expectations, but capable of being demonstrated in practice.Daniel holds a Master of Arts in Compliance (with Distinction) and a Bachelor of Arts in Law & Justice. He is a Certified Anti-Money Laundering Specialist (CAMS) and has completed the Canadian Securities Course, Partners, Directors and Senior Officers Course and Chief Compliance Officer Exam.He is based in Victoria, British Columbia, where he lives with his family.
TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]
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TrustPoint Compliance Advisors Ltd.
We design, build and test regulator-ready compliance programs — so you can lead with clarity and confidence.Contact / [email protected]