Who must be trained for FINTRAC, and how often?
Quick answer
Employees, agents, mandataries and other persons authorised to act for a reporting entity must get ongoing compliance training1. FINTRAC's guidance says to include people who deal with clients or transactions, handle cash or funds, or oversee the program2. It gives examples of how often but sets no single interval2.
On this page
Who must be trained?
The Regulations say that if you have employees, agents or mandataries, or other persons authorised to act on your behalf, you need a written, ongoing training program for them1. FINTRAC defines a mandatary as a person who acts, under a mandate or agreement, for another person or entity2.
FINTRAC's guidance says the plan should include people who2:
- have contact with clients, such as front-line staff or agents
- are involved in client transaction activities
- handle cash, funds or virtual currency for you in any way
- are responsible for implementing or overseeing the program, such as the compliance officer, senior management, IT staff or internal auditors
A sole proprietor with no employees, agents or other authorised individuals does not need a training program or plan for themselves2.
Which businesses does this apply to?
The compliance program rule applies to all reporting entities2. FINTRAC's list of reporting entities includes accountants and accounting firms (for certain activities), casinos, and dealers in precious metals and precious stones3. Check FINTRAC's page for your own sector.
Does the size of the business change who is trained?
It changes how, not whether. FINTRAC says the program and plan should be tailored to your size, structure and complexity, and your exposure to risk2. A large business may give different training by role, such as general or specialised training, and should explain that in the plan2.
In a small business the owner can be the compliance officer2. That person still needs to understand the rules, and staff still need training if they deal with clients or money.
How often must people be trained?
This is where the pages are careful. The Regulations say "ongoing" and name no interval1. FINTRAC's guidance gives examples, then leaves the choice to you.
Training can run at regular intervals, when events happen, or both, and FINTRAC's guidance gives examples rather than one required interval2.
| Question | What the pages say | Source |
|---|---|---|
| Does the law name an interval? | It says "ongoing" and gives no interval | 1 |
| What does the guidance suggest? | Regular intervals (for example monthly, semi-annually, annually), certain events (for example before a new employee deals with clients, or after a procedure changes), or both | 2 |
| What should the plan record about frequency? | The plan should describe the frequency of the program | 2 |
| What does FINTRAC check? | When and how often training takes place | 4 |
| How often is the whole program tested? | At least every 2 years, and that review covers the training program and plan | 2 |
The last row is not a training interval. The 2-year review tests the program; it does not replace regular training2.
What does "ongoing" mean in practice?
FINTRAC says training is delivered to give people an appropriate level for their duties and position, on an ongoing basis2. Records show you are doing it on an ongoing basis: the date, the attendees and the topics2. Two events the guidance names are a new employee about to deal with clients and a changed procedure2.
Where do the official pages say nothing?
We read the Regulations and FINTRAC's compliance program guidance, and also its assessment manual. They do not state:
- a required number of training hours
- a single fixed interval, such as every year
- that FINTRAC approves or accredits a particular course or provider
- a pass mark or a test result you must reach
FINTRAC does say its examiners may interview employees and agents to check they understand their duties and have received adequate ongoing training4. If you need an answer on any point above, ask FINTRAC. This guide is general information and not legal advice.
What should you do next?
Write down who is trained, on what, by which method and how often, and keep a record of each session. The FINTRAC kit gives you editable documents for that. For the full list of what the program and plan must include, see what a FINTRAC training program must include. If your team also pays supplier invoices, how to check a change to a supplier's bank details and the payment fraud kit cover a related risk.
Frequently asked questions
Do new staff need training before they deal with clients?
FINTRAC's guidance gives "before a new employee deals with clients" as an example of an event that can trigger training2. It is an example, not a stated rule.
Do contractors need to be trained?
The Regulations cover employees, agents, mandataries and other persons authorised to act on your behalf1. Whether a contractor is covered depends on whether they act for you. Ask FINTRAC if you are unsure.
Is once a year enough?
The pages do not say. Annual training is one example of a regular interval2, and the plan must fit your size and risk2.
Does a certificate from a course prove my staff are trained?
The pages do not say a certificate is enough. FINTRAC may interview employees to confirm they understand their roles and have had adequate ongoing training4, so keep a record of what was taught2.
Can a sole proprietor skip training?
Only if there are no employees, agents or other authorised individuals. Then no training program or plan is needed for themselves2.
Sources
Each number in the text links to the document the fact comes from. We keep a dated copy of every source with its SHA-256 fingerprint, so we can show what it said on the day we checked it.
- Source 1: Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184), section 156. Department of Justice Canada (Justice Laws Website), checked 2 November 2026.
https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-184/section-156.html - Source 2: Compliance program requirements: FINTRAC's compliance guidance. Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), checked 2 November 2026.
https://fintrac-canafe.canada.ca/guidance-directives/compliance-conformite/Guide4/4-eng - Source 3: Who must report to FINTRAC. Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), checked 2 November 2026.
https://fintrac-canafe.canada.ca/reporting-declaration/info/re-ed-eng - Source 4: FINTRAC assessment manual: the approach and methods used during examinations. Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), checked 2 November 2026.
https://fintrac-canafe.canada.ca/guidance-directives/exam-examen/cam/cams-eng
Aptia Skills is a private training company. It is not connected with any bank, police force, regulator, FINTRAC or government, and this guide is general information, not legal or financial advice.