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Speaking Notes for Tina Matos, Deputy Director of Supervision and Chief Compliance Officer, Financial Transactions and Reports Analysis Centre of Canada at The Assembly Canada (ACAMS)

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

Speech

Toronto, Ontario

October 9, 2026

Check against delivery

Introduction

I want to begin by thanking ACAMS for bringing us all together. I also want to thank all the compliance professionals, risk specialists and reporting entities who are here and who work every day to help protect Canada's financial system from money laundering, terrorist financing and sanctions evasion.

You had an opportunity yesterday to hear from my colleagues on the FATF Evaluation and what its findings mean for Canada's Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) Regime.

Today, I would like to build on that discussion and share FINTRAC's perspective as Canada's financial intelligence unit and AML/ATF supervisor.

First, I want to thank the FATF for this rigorous evaluation. I also want to recognize the considerable effort across Canada's broader regime, including the contribution of the private sector, throughout this process. I see that many of you are here today, and I thank you for your contribution. We, as Canada, succeeded together.

I think I can speak on behalf of everyone involved: mutual evaluations are demanding! But they give us something important: an independent assessment of where a regime is working well and, just as importantly, where more needs to be done.

We welcome this evaluation. It shows us the robustness of our regime, across a range of technical and effectiveness measures.

It tells us where Canada is achieving strong results and where we need to do more – a "roadmap" of sorts that we can use to our advantage as we continue to mature as a regime.

I am pleased to highlight that a number of these findings relate to work that we already have underway. So, as we look ahead, we are already delivering some of what we are called to do.

Today, I want to focus on three things:

At the centre of all this is risk: how we understand it, respond to it and demonstrate that our actions are effective.

FINTRAC's Key Takeaways from the FATF Evaluation

I know that yesterday's session gave you some solid insight into the findings published in the FATF Evaluation Report.

From FINTRAC's perspective, there are many findings that Canada's Regime should be proud of.

One clear example is the quality and value of our financial intelligence.

The evaluation recognized that FINTRAC's financial intelligence is, to a very large extent, supporting the operational needs of Canada's law enforcement and national security agencies.

Specifically, the evaluation found that FINTRAC generates high-quality financial intelligence that is valued by law enforcement from around the country and used in 94% of their investigations into money laundering and criminal possession offences.

Our recent results from the last fiscal year reinforce that finding.

Last year, FINTRAC produced 7,214 financial intelligence disclosure packages, based on 3,007 unique disclosures, the largest number the Centre has generated in a single year. Those disclosures included more than 1.6 million financial transactions and 10,650 subjects of interest to law enforcement.

Our financial intelligence contributed to 348 major, resource-intensive investigations, as well as many hundreds of other individual investigations at the municipal, provincial and federal levels across Canada and internationally.

Those are significant results, and they start with you and the committed work that you do as reporting entities.

The quality of our financial intelligence depends on the information we receive from businesses across Canada.

The reports you provide allow us to identify connections, uncover financial networks, and provide actionable intelligence to law enforcement and national security partners.

I want to take this opportunity to thank the reporting entities in this room. You are an essential part of Canada's Regime.

And your participation throughout the evaluation process was critical. Your engagement helped demonstrate how Canada's AML/ATF framework operates in practice.

A FATF Evaluation is also designed to show us where we can do better.

From FINTRAC's perspective, we agree there is more work to do. There is always more work to do. The threat landscape is continuously changing – and we need to continuously adapt and evolve.

Thankfully, many areas identified in the FATF report highlight work that is already underway.

Most notably:

That last point is important, and I'll return to it.

What I want to tell you all is this: coming out of the FATF Evaluation, we will not simply respond to the individual findings but we will use these findings to accelerate and guide our modernization.

Modernizing FINTRAC's Supervision

Let me start with how we, as an organization, are modernizing. As you know, FINTRAC is undergoing significant transformation.

The 2026 Spring Economic Update allocated $17.9M over four years to strengthen FINTRAC's ability to detect and disrupt illicit financing linked to extortion and fentanyl trafficking. This includes ensuring appropriate resources to support dedicated liaison officers to work with local law enforcement in the most affected areas, and support to the Countering Extortion Partnership, both initiatives underway since February.

As part of this funding, the Government has also directed FINTRAC to develop and consult on a Technology and Artificial Intelligence Roadmap – part of broader AML modernization.

This is a key initiative to ensure we are keeping up with the evolving landscape.

The Spring Economic Update also advances the creation of a Financial Crimes Agency, supported by $352.7M over five years and $82.1M ongoing, with a mandate to investigate serious and complex financial crimes and to recover the proceeds of crime. FINTRAC's financial intelligence will be central to the success of the agency's investigations and recovery work.

In relation to FINTRAC's Supervision, the Minister of Finance and National Revenue approved an increase in our overall cost-recovered envelope. From base funding of roughly $60 million in 2025–26, our funded amount will increase by approximately $25 million this fiscal year, to an overall funding envelope of $85 million. This increase will allow us to enhance our supervisory effectiveness, including:

This influx of funding represents a generational change for my team. It will enable us to scale our work, enhance our tools and analytics and mature our supervisory model. With this funding, my intention is to focus on key vulnerabilities in higher-risk areas: to dig deeper where it matters most.

Together, these investments and regulatory changes give us significantly greater capacity, better information and a broader range of supervisory and enforcement tools.

And what will matter is how we use these changes to focus on outcomes and bolster our Supervision modernization. This brings me back to the FATF Evaluation. The evaluation identified areas where Canada can strengthen its approach to risk-based supervision and enforcement. Our current transformation gives us an opportunity to address those findings in a very practical way.

Additional resources will allow us to increase the depth of our supervision in areas of greater risk.

Universal Enrolment and our new authorities will provide us with better information to assess risk, therefore deepening our understanding of the entities we supervise.

Modernized technology with stronger analytical capabilities will help us make better use of that information and translate it into supervisory decisions.

And our enhanced enforcement framework will give us more flexibility to respond effectively and proportionately when we identify non-compliance.

From FATF to a Stronger Risk-Based Approach

One of my key takeaways from the FATF Evaluation is that it must be crystal clear that all our supervisory activities flow concretely from a risk-based understanding and are closely documented. From operational planning to examinations to outcomes. 

We are collectively – as an international community – working together to define what this looks like in practice. The FATF's 2021 Guidance on Risk-Based Supervision gives us an approximate roadmap. The incoming FATF President has placed risk-based supervision as one of his top priorities. We, as a country, have the opportunity to help shape this globally. Canada – indeed, my team – will be a key partner in this work.

The modernization plan that I have described today puts FINTRAC in a much stronger position to move forward. 

For us, a stronger risk-based approach means leveraging technology to ensure a more complete and dynamic understanding of risk across the entire reporting population and using that understanding to determine where we focus resources and supervisory intensity. Universal enrolment will be a game changer for us.

These investments will allow us to bring together a broader range of information, including what we learn through examinations, the effectiveness of compliance controls, reporting and data-quality concerns, enforcement history, voluntary disclosures of non-compliance, intelligence and information from our partners.

With stronger technology, data, and analytics, we will be able to use that information to better understand risk at both the sector and entity level and refine that understanding as risks evolve.

The result will be a much clearer documented connection between the risks we identify and the supervision we undertake.

Where risk is lower, our approach may focus on compliance promotion, guidance or monitoring. As risk increases, the depth of our supervisory engagement will as well. And, where we identify significant or persistent non-compliance, we will have stronger enforcement tools available.

Risk will determine where we focus, how deeply we look and how we respond.

This does not mean replacing professional judgement with a one-size-fits-all model. We will continue to assess the evidence, consider the circumstances of individual entities and exercise our expertise.

Ultimately, this is how I see modernization helping us respond to the FATF Evaluation: giving us the capacity, information and tools to direct the right level of supervisory attention to the right risks at the right time.

What Reporting Entities Should Expect

As we build this approach, I want to be clear about what reporting entities should expect from FINTRAC.

I want FINTRAC to be predictable, transparent and fair.

Reporting entities should understand our expectations and have clarity about how we approach supervision.

We should be transparent about what we are seeing across the sectors we supervise, where risks are emerging, and what we expect in response.

And our approach should be reasonable and proportionate.

We recognize the diversity of sector risk and vulnerabilities that our reporting entities operate in. You differ in size, complexity, and business models.

Your risks are different, and our approach to supervision should reflect those differences.

I want to be clear that being reasonable is not being passive.

We must be firm when we identify non-compliance and we must be intrusive where the level of risk requires it.

It is the balance that is important.

A risk-based supervisor should focus attention where the exposure and consequences are greatest. And, when we intervene, that intervention should reflect the risk and the compliance issue we are addressing.

Our expanded supervisory and enforcement toolkit will give us greater flexibility to do that.

Where appropriate, our focus may be on compliance promotion or remediation. In other circumstances, stronger intervention may be required.

Our objective is not enforcement for the sake of enforcement.

Our objective is to work together to encourage the right behaviours, address deficiencies and achieve compliance.

For me, that is what a mature risk-based supervisor should look like: clear in its expectations, proportionate and prepared to act decisively where warranted.

And there is an important connection between what we expect of ourselves and what we expect of the entities we supervise. As FINTRAC strengthens its own risk-based approach, we need reporting entities to do the same.

What We Expect from Reporting Entities

I ask all businesses to know your risks, document them clearly and make sure they are driving your compliance program.

A risk assessment should not simply exist because it is a regulatory requirement.

It should reflect the realities of your business and provide a clear picture of your exposure to money laundering, terrorist financing and sanctions evasion risks.

That means understanding where those risks come from and ensuring that your assessment is supported by the information available to you.

The risks you identify should inform all aspects of your compliance program.

And as your business and the risk environment evolve, your compliance program should evolve with them.

Different sectors face different vulnerabilities. And, even within the same sector, businesses can have very different risk profiles based on their products, customers, geographic exposure, delivery channels and business models.

What we expect is that you can demonstrate a clear and defensible connection between the risks you have identified and the measures you have put in place to address them.

That connection is fundamental to effective compliance.

Connection back to FATF Evaluation

When I look at where we are today, I see an important moment for FINTRAC and for Canada's Regime.

The FATF Evaluation has given us an independent assessment of our strengths and the areas where we need to improve.

At the same time, FINTRAC is receiving significant new resources, authorities, information and tools.

Our responsibility now is to bring those pieces together. With you.

For FINTRAC's Supervision program, that means using technology to sharpen our documented understanding of risk and become more targeted in where we focus our attention.

It means having more data and information to support our decisions.

It means having a broader range of tools to respond proportionately when we identify deficiencies.

And most importantly, it means maintaining a focus on whether our interventions are contributing to stronger compliance.

This is how I believe we can meaningfully respond to the FATF Evaluation.

Not simply by addressing individual recommendations in isolation, but by continuing to mature the supervisory system that sits behind them.

Conclusion

I want to reiterate that the strength of our Regime depends on all of us. Working together.

There is a direct connection between your work, the work of your compliance teams, our supervisory work and the broader results that our Regime is trying to achieve.

I want to leave you with three thoughts.

First, Canada has a strong foundation.

The FATF Evaluation recognized important strengths, including the quality and operational value of FINTRAC's financial intelligence. The reporting entities represented here today are an essential part of that success.

I want to thank you for that contribution and for your engagement throughout the evaluation process. 

Second, we have a significant opportunity in front of us.

FINTRAC's Supervision program has additional resources, new authorities, better information and stronger supervisory and enforcement tools.

The FATF Evaluation reinforces that transformation matters and where we need to focus.

Third, we need to keep risk at the centre of what we do.

For FINTRAC, that means using technology and data to direct our supervisory attention where it can have the greatest impact. To leverage technology to document the flow through from risks – to action – to outcomes.

It means being predictable and transparent in our supervision, reasonable in our approach, firm when we identify non-compliance, and appropriately intrusive where risks are greatest.

For reporting entities, it means understanding your risks, documenting them clearly and ensuring that they are genuinely shaping your compliance program.

Ultimately, our shared objective remains the same: to protect Canada's financial system and contribute to the detection, deterrence and disruption of money laundering, terrorist financing, sanctions evasion and other financial crimes.

We all have a role to play in achieving this, and I look forward to continuing that work with you.

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