FINTRAC Supervision Now Has a Price Tag: Why You’re Getting Invoiced (and What It Means)
If you recently received an invoice from FINTRAC and found it confusing, you are not alone. Many reporting entities have asked the same questions: what is this charge, why am I paying it, and does it mean something is wrong?
FINTRAC invoices have become a new point of confusion for many Canadian reporting entities. The confusion is understandable. For years, organizations associated FINTRAC interactions with examinations, findings, or enforcement. A sudden invoice can feel like a signal.
In most cases, it is not.
As of April 1, 2024, FINTRAC began recovering the annual cost of its Supervision (compliance) program from certain reporting entities through a regulated “assessment of expenses” model. This is commonly described as cost recovery.
This assessment is not an administrative monetary penalty (AMP). It is not tied to examination findings. It does not mean something is wrong with your anti-money laundering and anti-terrorist financing (AML/ATF) program.
Why FINTRAC Is Invoicing Reporting Entities
Before April 1, 2024, FINTRAC’s supervision function was primarily funded through general government appropriations. Under the current model, supervision costs are recovered from certain reporting entities using methods set out in regulation.
FINTRAC has published public guidance explaining how the charging model works, how invoices are issued, and how amounts are calculated. Organizations should treat these invoices as an administrative charge tied to supervision funding, not a supervisory warning.
AMLI Analysis: the charge exists to fund supervision infrastructure. It is not designed to punish non-compliance.
Resources:
- FINTRAC: Charging reporting entities for FINTRAC’s compliance program
- FINTRAC: Components of the method for charging reporting entities
- Justice Laws: Assessment of Expenses Regulations (SOR/2023-195)
What FINTRAC Fees Cover (and What They Do Not)
FINTRAC supervision covers the operational work required to oversee compliance with Canada’s AML/ATF regime. The cost recovery model is designed to fund the supervision program’s operating capacity. This typically includes supervisory operations, staffing, and systems used to administer supervision activities.
Just as importantly, these assessments are not:
- fines or penalties (AMPs)
- tied to your examination outcome
- discretionary surcharges based on compliance quality
- an indicator of a deficiency in your compliance program
FINTRAC’s guidance is clear that invoices are part of the charging model and should be interpreted as program charges, not enforcement notices
Who Pays: Prescribed Reporting Entities Only
Not every reporting entity is assessed under the same approach.
The regulation prescribes:
- which entity types are subject to assessments, and
- how the assessment is calculated for those entity types.
In general terms, the model uses proxies for scale and activity, commonly:
- Canadian asset values (for certain prescribed categories), or
- transaction reporting volumes (for other prescribed categories).
These inputs are just calculations. They are not risk ratings and do not reflect the quality of your AML/ATF controls.
How FINTRAC Calculates What Each Entity Pays
At a high level, FINTRAC:
- determines the total annual cost of its supervision program, then
- allocates that cost across prescribed reporting entities using the method set out in regulation.
In simple terms, entities with larger footprints or higher activity levels bear a larger share of the supervision cost.
AMLI recommendation: your invoice should be readable as a formula outcome. It should not be treated as a subjective decision by FINTRAC.
Interim vs Final Assessments: Why the First Year Confused Many Organizations
The first fiscal year under the model required interim billing mechanics.
In practice, cost recovery models often rely on:
- interim assessments based on forecasted program costs and the most recent available data, then
- final assessments once actual audited costs and updated input data are available.
This process can create reconciliation outcomes such as:
- additional amounts owing for some entities,
- reimbursements for others, or
- minimal changes where interim and final values align closely.
AMLI Analysis: “Adjustments” are often a normal by-product of interim and final assessment mechanics. They are not automatically evidence of an error or an issue.
Why Reporting Volume Now Matters More Operationally
Reporting obligations themselves have not changed. Thresholds, report types, and submission requirements remain defined under the AML/ATF regime.
What has changed is visibility.
For certain prescribed entities, reporting volume is used as an allocation input in the cost recovery model. That means reporting data is no longer only a compliance artifact. It can become a finance-visible metric tied to a recurring cost line.
What to do internally
- Align compliance reporting metrics with finance and general ledger narratives.
- Ensure you can explain variances, such as business growth, new products, onboarding changes, or clearing a backlog.
- Treat the invoice as a calculated outcome and align internal teams around the inputs and method behind it
Practical Takeaways for Finance and Compliance Teams
FINTRAC supervision assessments should be treated as:
- a recurring operating cost, and
- a predictable annual cycle involving interim assessments and later reconciliation.
Minimum internal readiness usually includes:
- a short internal explainer that finance can repeat consistently
- a clear understanding of what input drives your category (assets vs reporting volumes)
- a process to validate the data you track internally against what you submitted and retained in records
Organizations that can explain invoices clearly tend to experience less internal friction. The aim is to make the process easier to interpret, explain, and document.
What This Does Not Change
This funding model does not:
- change AML/ATF legal obligations
- change reporting thresholds
- reflect examination outcomes or risk ratings
- operate like an AMP or enforcement action
It is an administrative funding mechanism designed to fund supervision capacity.
FAQs: FINTRAC Supervision Fees and Invoices
Why did I receive a FINTRAC invoice?
If your entity is prescribed under the Assessment of Expenses Regulations, you may be assessed to fund FINTRAC’s supervision program. The invoice reflects a charging model, not an enforcement action.
Is a FINTRAC invoice a penalty?
No. An assessment is separate from an administrative monetary penalty (AMP). An invoice under the charging model is a program charge, not an enforcement notice.
Does receiving an invoice mean FINTRAC found deficiencies?
Not inherently. Being invoiced does not mean FINTRAC has identified a deficiency in your AML/ATF program.
What is an interim assessment vs. a final assessment?
An interim assessment is typically based on forecasted costs and recent data. A final assessment is calculated once audited costs and updated inputs are available, and it reconciles amounts already paid.
Why does my invoice include an adjustment?
Adjustments commonly reflect reconciliation between interim and final calculations or corrections tied to updated inputs. In many cases, this is the expected mechanics of the model.
Getting Support
FINTRAC supervision assessments follow a set method. Confusion usually comes from internal coordination gaps.
AML Incubator supports reporting entities by making supervision fees explainable, forecastable, and audit-ready:
- Invoice interpretation and internal briefing support
Translate line items (interim vs. final), key inputs, and calculation logic into a CFO-ready explanation. - Reporting data and metric alignment
Align compliance reporting volumes, finance records, and operational metrics so assessments are predictable and defensible.
Regulatory readiness and evidence pack reviews (blog)
Identify documentation gaps and governance weaknesses that create friction in supervisory interactions before they surface.
