For businesses FINTRAC training kit
Compliance training program and plan kit for FINTRAC reporting entities.
A Word kit for Canadian real estate brokers and developers, accountants, dealers in precious metals and stones and money services businesses: a written, ongoing training program, a yearly training plan, role-by-role outlines, a training register, a briefing on AI-assisted scams and a staff sign-off sheet. Filled in with your details. CAD 129, instant download.
From CA$129 · one-off payment · instant Word download
- A written, ongoing compliance training program that says who is trained, on what, how it is delivered and how often, in the shape FINTRAC describes for the training program and plan.
- A yearly training plan with a calendar you fill in, and role-by-role training outlines for the people who deal with clients, handle funds, oversee the program or look after your systems.
- A training register and a staff acknowledgement sheet, so every session leaves a dated record of who attended and what was covered.
- A briefing on payment redirection, identity fraud, fake documents and deepfakes, with Canadian places to report, and a checklist for the training part of your two-year effectiveness review.
Aptia Skills
Compliance training program and plan kit
Prepared for: Example Harbourview Realty Ltd.
- Start here: how to use this kit
- Written ongoing compliance training program
- Yearly training plan
- Role-based training outlines
- Training register
- Emerging risks briefing: AI scams, deepfakes, identity fraud and payment redirection
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What is inside.
Every document, filled in with your details, in one Word file you can edit.
Compliance training kit 8 documents
- GuideStart here: how to use this kitWhat is in the kit, what it can and cannot do, your set-up in one table, the steps to put it in place and an evidence file index.
- PolicyWritten ongoing compliance training programThe written program: who is trained, on what, how it is delivered, how often, and which records are kept.
- PlanYearly training planThe documented plan for delivering the training program: who is trained, on what, how, when and from what materials.
- GuideRole-based training outlinesA training outline for each role in your business: what the person must know, what to practise and what to check.
- RegisterTraining registerA dated record of every training session, who attended, what was covered, and who is due next.
- GuideEmerging risks briefing: AI scams, deepfakes, identity fraud and payment redirectionA staff briefing for the training session: payment redirection and identity fraud first, then AI-written messages and deepfakes, with Canadian places to report.
- RegisterStaff acknowledgement sheetA sheet each person signs to confirm they have been trained, know who the compliance officer is and know how to raise a concern.
- ChecklistEffectiveness review checklist: training program and planA checklist for testing the training program and plan as part of the two-year effectiveness review, with interview questions and an action plan.
See a real page.
This is what a page looks like, filled in for an example business.
1. Written ongoing compliance training program
Purpose
Example Harbourview Realty Ltd. trains its people so that they know and understand what the law requires of the business, how the business could be used for money laundering or terrorist activity financing, and what each person must do about it. This document is Example Harbourview Realty Ltd.’s written, ongoing compliance training program. The yearly training plan sets out how the program is delivered. (FINTRAC, Compliance program requirements, section 6 (training); FINTRAC, Compliance program requirements)
Scope
This program applies to Example Harbourview Realty Ltd. and to every employee, agent, mandatary and other person authorized to act on its behalf, including the compliance officer (Priya Nair, Broker of Record), senior management and owners, information technology staff, and contractors who deal with clients or funds.
This program covers training only. Example Harbourview Realty Ltd.’s compliance policies and procedures, risk assessment and know-your-client steps are written separately; the training teaches them. (FINTRAC, Compliance program requirements)
Our policy
- Example Harbourview Realty Ltd. maintains this written, ongoing compliance training program for all the people named in the scope.
- Each person receives an appropriate level of training for their duties and position, on an ongoing basis.
- The program is tailored to the size, structure and complexity of Example Harbourview Realty Ltd. and to its exposure to money laundering, terrorist activity financing and sanctions evasion risk. It is not a generic course.
- Training is delivered as set out in the yearly training plan, and a record is kept of every session.
- Every person is told who the compliance officer is (Priya Nair, Broker of Record) and how to raise a concern at any time. (FINTRAC, Compliance program requirements, section 6 (training))
Our suggestion: staff who join Example Harbourview Realty Ltd. are trained before they deal with clients or handle funds. FINTRAC gives training before a new employee deals with clients as an example of event-based training. (FINTRAC, Compliance program requirements, section 6 (training))
What the training covers
The program explains what people need to know and understand:
- The requirements that apply to Example Harbourview Realty Ltd. under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its Regulations.
- Background on money laundering and terrorist activity financing: what they are and the methods used.
- How Example Harbourview Realty Ltd., as a business in its sector, could be vulnerable, with indicators and examples.
- The compliance policies and procedures Example Harbourview Realty Ltd. has developed, including reporting, record keeping and know-your-client requirements.
- Each person’s roles and responsibilities in detecting and deterring money laundering and terrorist activity financing, and what to do with a potentially suspicious activity or transaction. (FINTRAC, Compliance program requirements, section 6 (training))
FINTRAC says it pays close attention to the training given on detecting suspicious transactions, and it focuses on whether the training helps staff understand the requirements, the policies and procedures, and indicators and trends. Example Harbourview Realty Ltd. therefore adds the following, which also reflects that fraud against the business is how many staff meet financial crime in practice. (FINTRAC, Assessment manual, 3.1.4 (training))
- Recognizing a suspicious transaction: the reasonable-grounds-to-suspect threshold, attempted as well as completed transactions, reporting as soon as practicable, and not telling the client about a report.
- Verifying client identity, and spotting identification that cannot be authenticated, is inconsistent, or looks counterfeited or altered.
- The emerging risks briefing: payment redirection, identity fraud and fake documents, AI-written messages, and voice and video deepfakes.
- Record keeping: what is kept, and that records must be kept so they can be provided to FINTRAC within 30 days of a request.
- Changes to the law, to FINTRAC’s guidance or to Example Harbourview Realty Ltd.’s procedures since the last session. (FINTRAC, Reporting suspicious transactions; FINTRAC, ML/TF indicators (real estate); FINTRAC, Record keeping (by sector))
A step-by-step outline for each role is in the “Role-based training outlines” document.
Who is trained
Training recipients include people who have contact with clients, are involved in client transaction activities, handle cash, funds or virtual currency for the business in any way, and are responsible for implementing or overseeing the compliance program. (FINTRAC, Compliance program requirements, section 6 (training))
Example Harbourview Realty Ltd. trains these roles:
The rules, in brief.
What the official sources say, word for word checked.
If you have employees, agents or mandataries, or other persons authorized to act on your behalf, you must develop and maintain a written, ongoing compliance training program.
You must institute and document a plan for your ongoing compliance training program and for delivering the training.
The training plan should include information on four things: training recipients, training topics and materials, training methods for delivery, and training frequency.
Training recipients should include people who have contact with clients, are involved in client transaction activities, handle cash, funds or virtual currency for you in any way, and are responsible for implementing or overseeing the compliance program (such as the compliance officer, senior management, information technology staff or internal auditors).
The training program should include a record of the training delivered (for example the date, a list of attendees and the topics covered). The records help you schedule the next training and show that you carry out the program on an ongoing basis.
A sole proprietor with no employees, agents or other individuals authorized to act on their behalf is not required to have a training program or a training plan.
For the training program and plan, FINTRAC looks at who receives training, what topics are covered, when and how often training takes place, how the program is implemented and how training is delivered.
Sources: FINTRAC, Assessment manual
The effectiveness review must be conducted every 2 years at a minimum, to test the effectiveness of the policies and procedures, the risk assessment, and the ongoing training program and plan.
How it works.
- Answer a few questions about your organisation. It takes about three minutes.
- Pay once on Stripe, our payment company.
- Download your Word file straight away, then adapt it to how you really work.
Who it is for
- Real estate brokers, sales representatives and developers, accountants and accounting firms, dealers in precious metals and precious stones, and money services businesses in Canada that have employees, agents or mandataries.
- Owners and compliance officers who know they need a written training program and plan, but have only informal or verbal training today.
- Businesses that want one dated file showing what their training program is, who has been trained, and when.
Who it is not for
- Anyone who wants legal advice, or a promise about what FINTRAC will find in an examination.
- Sole proprietors with no employees, agents or other individuals authorized to act for them: FINTRAC says they are not required to have a training program or plan.
- Banks, securities dealers, casinos and other sectors. The kit is written for the four sectors above.
- Businesses that will not deliver the training. A written program that is not put into practice does not meet the duty.
What these documents can and cannot do
- These are starting documents. Adapt them to how your business really works, and deliver the training.
- FINTRAC looks at what you actually do: who was trained, on what, and whether people understand their roles. Papers alone are not enough, and no kit can promise an examination result.
- This is not legal advice, and it is not connected with FINTRAC or any government body. The kit covers the training program and plan, not your full compliance program (policies, risk assessment, know-your-client steps, reporting).
- It is not a course. It gives you the program, the plan, outlines and records; you deliver the sessions with your own policies and the free FINTRAC guidance it points to.
Build your documents.
Your answers go into the documents. Nothing else is asked.
Questions.
Does the law really require a written training program?
Yes, if you have employees, agents or mandataries, or other persons authorized to act for you. FINTRAC says you must develop and maintain a written, ongoing compliance training program and a documented plan for delivering it. The page lists the sources, with the exact words we checked.
Will this pass a FINTRAC examination?
No document can promise that. FINTRAC looks at who receives training, what topics are covered, how often training takes place and how it is delivered, and it may interview your staff. The kit gives you the written program, plan and records; the training must really happen.
Who has to be trained?
People who deal with clients, take part in client transactions, handle cash, funds or virtual currency, or oversee the compliance program. That is how FINTRAC describes training recipients. The questionnaire asks which of these roles you have, and the kit builds the program and the role outlines from your answers.
Is this the same for every sector?
The training duty is the same for every reporting entity. The examples and sector rules differ. The kit adds sector wording for real estate brokers and developers, accountants, dealers in precious metals and precious stones, and money services businesses.
What does it say about AI scams and deepfakes?
It leads with payment redirection and identity fraud, which are common, and treats deepfakes as an emerging risk. The briefing uses the Canadian Anti-Fraud Centre’s warnings and the reported figures with their dates, and gives staff calm habits: call back on a number you already hold, ask a second person, and slow down.
What do you ask me, and what do you keep?
Only business details. We ask for your business name, province, sector, the name and role of your compliance officer, how many people you train, which roles you have and how you deliver training. We never ask for client information, staff personal details or identity documents.
Can I edit the documents?
Yes. You receive one Word file (.docx). Open it in Word, Google Docs, Pages or LibreOffice. Change anything that does not match how you work, and add your logo.
Are the examples real?
No. Every name, business and web address in the examples is invented. The only real organizations named are the public bodies whose guidance we cite, as plain text.
Is it written by a person or by AI?
It is written with AI, using the FINTRAC and Canadian Anti-Fraud Centre pages listed on this page, and every rule and number is checked word for word against them. Each one carries a short reference to its source. Things that are only our suggestion, such as how often to run sessions, are marked as suggestions so you can change them.