Workshop B — The Mock Exam: Preparing for FINTRAC Examinations and Managing Competing International Compliance Expectations
Asad Rauf
Senior Vice President, Chief Compliance Officer, Chief Anti-Money Laundering Officer
SBI Canada Bank
Charles Victor Gonzales
Director, AML Regulatory Compliance
Digital Commerce Bank
With enforcement actions becoming more public, preparing for a FINTRAC examination is no longer a “nice-to-have”. This interactive mock exam will walk you through what FINTRAC actually tests: your compliance program, reporting, client ID, record keeping, and third-party determination, and how to respond when findings land.
Part One: Maintaining an Audit Ready Program
- Applying FINTRAC’s risk-based lens to strengthen your program and evidence trail
- Testing documentation quality so decisions are defensible under scrutiny
Part Two: Preparing for an FINTRA Exam or Effectiveness Testing
- Walking through the exam stages and what FINTRAC checks most closely
- Identifying the most common gaps that drive negative results and penalties
Part Three: Managing the Exam/Testing
- Preparing a “document request pack” and interview-ready materials for a mock exam
- Readying internal protocols for lawful information sharing between reporting entities, including code-of-practice expectations
Part Four: Implementing the Recommendations
- Practicing response drafting to findings, remediations plans, and follow-through
Part Five: Meeting International Requirements Without Breaking the Canadian Program
- Comparing expectations across key foreign regimes (e.g., Dubai/DFSA, Switzerland/FINMA, and other major jurisdictions) with a practical “what changes” lens
- Managing group-wide standards and local Canadian requirements without creating conflicting controls
- Applying the Canadian regime to foreign-owned banks and cross-border operating models
- Assessing risk when working with foreign financial institutions, platforms, and counterparties