An examination is FINTRAC's mechanism for checking whether a reporting entity's compliance program is real: not just written down, but actually followed. For a dealership or leasing company (in scope since April 1, 2025, with FINTRAC's first-year grace posture over as of April 1, 2026) it's worth understanding the sequence before it happens rather than during it.

Stage 1: Notice and document request

Examinations usually begin with a written notice and a request for documents, due back within a defined window. The first wave of documents requested is predictable (see our related post on what examiners ask for first) and centers on:

  • Your compliance program documents (policies, procedures, the compliance officer's name).
  • Your risk assessment.
  • Training records.
  • A sample of client and deal files, selected by the examiner, not volunteered by you.

Stage 2: File and record review

This is the core of the exam. The examiner checks your actual records against your own stated procedures and against FINTRAC's requirements: was identity verified using an acceptable method, was it done at the right point in the transaction, is the record complete and retained, was screening performed and documented, does the training record match the training policy?

This stage can be on-site, remote, or a mix: the format doesn't change what gets reviewed. What it tests is whether your paperwork exists at the individual-deal level, not just at the policy level. See our guide to client identification methods for what "acceptable" evidence looks like.

Stage 3: Findings and follow-up

After the review, FINTRAC communicates findings. These can range from minor recommendations to a formal action plan with deadlines, to administrative monetary penalties for confirmed violations: penalty ceilings Bill C-12 raised roughly 40-fold, with a missing compliance program classified as a very serious violation. In more serious cases, findings can be referred further.

Importantly, penalties attach to the violation itself (a missing risk assessment, unretained records, a compliance officer never appointed), not to whether any actual money laundering took place. A clean, honest business with a paper-thin program is still exposed.

How to actually be ready

The businesses that come through an examination cleanly share one trait: their records were built as a byproduct of doing business, not assembled afterward. Practically:

  1. Name your compliance officer and write the program documents now: this can happen in days, and it removes the most basic finding.
  2. Capture ID and screening evidence on every deal going forward: the sample an examiner pulls will be from your real transaction history.
  3. Keep training completions on record, not just a training plan.
  4. Run a self-check periodically: pull a few random deal files and see if you could hand them over in ten minutes, the way an examiner would ask.

The free 12-item readiness checklist mirrors this sequence, or Provasure keeps the evidence trail live so an exam notice is a non-event instead of a scramble.


Sources: FINTRAC's examination process and enforcement approach are described in its official guidance at fintrac-canafe.canada.ca. Always verify current process details against official guidance.