What Is a CAMLO? Role, Duties & Who Needs One in Canada (2026)
A CAMLO runs your AML compliance program. Learn what a CAMLO does, who can be one, FINTRAC's requirements, and when to outsource.
Quick answer: A CAMLO (Chief Anti-Money Laundering Officer) is the person responsible for running a business's anti-money laundering (AML) compliance program. In Canada, every reporting entity under the PCMLTFA, including money services businesses (MSBs), crypto platforms and many fintechs must appoint a compliance officer. "CAMLO" is the common industry title for that role.
What does CAMLO stand for?
CAMLO = Chief Anti-Money Laundering Officer.
You'll also see:
- Compliance Officer: the term FINTRAC uses in its guidance
- MLRO: Money Laundering Reporting Officer (common in the UK and EU)
- CCO: Chief Compliance Officer (often a broader role covering more than AML)
In Canada, the legal requirement is simply to appoint a person responsible for implementing your compliance program. Whatever title you use, the responsibilities are the same.
What does a CAMLO do?
A CAMLO owns your AML program from end to end. Day to day, that means:
- Building and updating the compliance program: written policies and procedures for KYC, record keeping, reporting, sanctions screening and the travel rule.
- Running the risk assessment: identifying where money laundering and terrorist financing risk exists in your clients, products, channels and geographies, and updating it when the business changes.
- Overseeing reporting to FINTRAC: suspicious transaction reports (STRs), large cash and large virtual currency reports, EFT reports and terrorist property reports.
- Training staff: maintaining a written, ongoing training program and keeping records of who was trained.
- Arranging the effectiveness review: an independent test of the program at least every two years.
- Handling FINTRAC examinations: acting as the main contact when FINTRAC reviews your business.
- Supporting banking relationships: answering bank due diligence questionnaires and explaining your controls.
- Reporting to senior management: keeping leadership informed about risks, gaps and fixes.
The CAMLO can delegate tasks to others, but remains accountable for the program as a whole.
Who needs a CAMLO in Canada?
Every reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act must appoint a compliance officer. That includes:
- Money services businesses (MSBs), including foreign MSBs serving Canadians
- Virtual currency / crypto dealers
- Payment service providers with MSB activities
- Securities dealers and financial entities
- Real estate brokers and developers, accountants, casinos, dealers in precious metals and stones, and other sectors covered by the PCMLTFA
If you're an MSB, FINTRAC asks for your compliance officer's details at registration, so you need one before you apply.
Who can be a CAMLO?
According to FINTRAC guidance:
- In a small business, the compliance officer can be a senior manager, the owner or the operator.
- A sole proprietor can appoint themselves.
- In a larger business, the compliance officer should come from a senior level and be able to communicate directly with decision-makers.
Whoever you appoint must have:
- Authority: the power to make and enforce compliance decisions
- Resources: enough time, budget and tools to do the job
- Knowledge: an understanding of your business and your sector's AML obligations
- Independence: ideally not directly involved in receiving or transferring funds
Why the CAMLO role matters more in 2026
The stakes went up sharply this year. Amendments to the PCMLTFA that came into force on March 26, 2026 allow FINTRAC to impose penalties up to 40 times higher than before, along with mandatory compliance agreements and compliance orders for serious violations.
In practice, a weak or "paper-only" compliance officer is now one of the costliest risks an MSB can carry. It's also one of the first things banks check before opening or keeping an account.
Read more: FINTRAC 2026 Legislative Amendments: What MSBs Must Know · FINTRAC's New AMP Framework (2026)
Common CAMLO mistakes FINTRAC and banks spot
- A CAMLO in name only: the founder is listed but has no time, training or AML background.
- No independence: the CAMLO also approves transactions or chases sales targets.
- Outdated program: policies written at launch and never updated.
- Missed effectiveness review: no independent review within two years.
- No records: training, risk assessment updates and decisions aren't documented.
Would Your Compliance Program Survive a FINTRAC Exam?
In-house vs outsourced CAMLO
| In-house CAMLO | Outsourced CAMLO | |
|---|---|---|
| Best for | Larger firms with high volumes and budget | Startups, small and mid-size MSBs, fintechs, crypto firms |
| Cost | Full-time salary + benefits + training | Fixed monthly fee |
| Experience | Depends on who you can hire | Access to a specialist who has handled many FINTRAC files |
| Speed | Hiring can take months | Can be in place quickly |
| Coverage | One person — gaps during leave or turnover | Team backup |
| Accountability | Your business stays responsible | Your business still stays responsible |
Important: outsourcing the CAMLO role doesn't outsource your legal responsibility. Choose a provider who works closely with your team and documents everything.
Frequently Asked Questions
What is a CAMLO?
A Chief Anti-Money Laundering Officer, the person responsible for running a business's AML compliance program and making sure it meets FINTRAC requirements.
Is a CAMLO legally required in Canada?
Yes. Every reporting entity under the PCMLTFA must appoint a compliance officer responsible for its compliance program. "CAMLO" is the common title for that role.
What's the difference between a CAMLO and an MLRO?
They're essentially the same role. CAMLO is the more common term in Canada; MLRO is more common in the UK and EU.
Can the business owner be the CAMLO?
Yes, in a small business or sole proprietorship. They still need the knowledge, time and authority to run the program properly.
Can I outsource my CAMLO?
Yes. Many MSBs, fintechs and crypto firms use an outsourced CAMLO. Your business remains responsible for compliance.
Do I need a CAMLO before registering my MSB with FINTRAC?
Yes. FINTRAC asks for your compliance officer's details as part of the MSB registration application.
Need a CAMLO?
AML Incubator provides experienced, FINTRAC-ready outsourced CAMLOs and MLROs for MSBs, fintechs and crypto companies across Canada so you can run a compliant AML program without hiring in-house.
Related: Outsourced CAMLO & MLRO Services · MSB Registration · The 5 Pillars of an AML Compliance Program
