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Stronger Together

Opening remarks from Outlier Compliance Group Co-Founder and Chairperson Amber D. Scott at TCAE 2025 Toronto Compliance & AML Conference

Many of us remember exactly where we were on this day 24 years ago. 

Imagine this scenario: I was a new compliance analyst at Manulife, having started my first role after university just a month before in the Waterloo head office. I had been at my desk since 7 am when a colleague, her face streaked with tears, came by to tell our team to assemble for instructions in one of the conference rooms. There was little information, but what was known was devastating; America was under attack, on home soil. 

Financial markets closed. Staff were sent home to await further instructions. When I went to my desk to pick up my handbag, my phone was ringing and I answered. It was a colleague in Toronto with mobility issues, who was not able to navigate the crowds at Union Station. So she had gone back to the office, which was now mostly empty, to wait, and she was terrified. We talked for two hours, until some of the crowds cleared.

While we were on the phone, my colleague and I would set our physical handset phones aside, and walk over to nearby meeting rooms to see if there were any updates on the news on the TVs there. It was 2001 – we couldn’t just Google it.

So much has changed since then. I think it’s fair to say that at the time, the idea of compliance was academically interesting, but if you asked me what I did – or why it mattered – neither money laundering, nor counter terrorism would have been top of mind. 

But some things strike me as being eerily similar – we talked to each other that day about what was happening and what it meant. In the days that followed, the most common question asked was what can we do to help? In the months and years that followed, how do we make sure that this doesn’t happen again? We refused to be paralyzed by fear, and sought to build more resilient systems, even if these were sometimes inconvenient.

Today, while I have many more sources of information at my fingertips, I am still very reliant on people in my network when I need to understand something at a deep level. While I don’t have to put down a handset and go to the meeting room next door to see what’s on the news, I am every bit as reliant on colleagues and contacts to parse information, understand implications, and find truth. 

Finding truth, in my estimation, is one of the greatest challenges of the modern era. The importance of truth cannot be overstated at a time when we are under continuous attack, pummeled with misinformation and disinformation, on a seemingly unending basis, from every possible direction, via every possible channel. On that score, I owe a huge debt to some of the folks in the room today, who have been unerring sources of insight, and of truth.

This is not an indictment of my own skills or abilities, but a call to the importance of communities, and knowledge sharing. Any one of us can be strong on our own, but no one can achieve a true level of badassery without community.

It is fitting then, that I am standing on this stage today with Souzan Ismaili, because no one builds community better than she does. Souzan is tireless in her quest to bring people together, to educate, and to create connections. 

I don’t think that the importance of this work can be understated – but this is not just Souzan’s work. This is a call to action to every person here today, to build community, to find your sources of truth, and to be that Northstar for your colleagues when you can. It won’t always be easy, in fact, sometimes it will be hard – but we will always be stronger together.

Outlier Compliance Group welcomes Maria Shamou!

The Outlier Compliance Group team is excited to welcome our newest member, Maria Shamou, as our administrative ninja.
Maria brings broad compliance knowledge complemented by over eight years of comprehensive customer service experience, paired with a strong foundation in administrative support and a strong interest in compliance along with a background in administrative support. She earned a Bachelor’s degree in Business Administration, and later completed a post-graduate program in Financial Services Compliance Administration at Seneca College. Through this program, she expanded her knowledge in anti-money laundering (AML) administration, risk management, privacy management, and financial services product knowledge. Her interest in financial services products led her to complete the Canadian Securities Course (CSC).

Maria is proud to support Outlier’s mission statement: “Good compliance is good business.”

 

We Turn 12!

Green foil balloons forming the number 12 with gold confetti on a light background, celebrating a 12-year anniversary.Today marks another milestone for us – 12 years since Outlier Compliance Group was founded.

What began as a bold and novel idea, building a consulting firm made up exclusively of seasoned compliance professionals with deep in-house experience, has grown into a thriving, trusted partner for clients navigating Canada’s ever-changing regulatory landscape.

Our name, inspired by Malcolm Gladwell’s “Outliers, the Story of Success” which espoused the notion that to be truly proficient in a skill, 10,000 hours of practice is required. That was the bar that was set, met, and most often exceeded by every compliance professional that joined our team over the years.

Over the years, we’ve grown, evolved, but have stayed true to our roots. We’ve learned that success comes from surrounding ourselves with exceptional people, from listening closely to our clients, and from being willing to adapt in the face of change. We’ve discovered the value of curiosity when navigating complexity, and the power of collaboration when tackling the most challenging problems.

Through it all, our mission has remained the same “good compliance is good business”. It’s the principle that guides our work, shapes our advice, and underpins every solution we deliver.

As the Canadian regulatory environment becomes increasingly complex, our mission and our learnings will play to our continued success and growth as we continue to provide top tier compliance and risk management services. 

To our amazing team, past, present and future, thank you for your passion, expertise and resilience. To our clients, partners and industry peers, thank you for your trust and collaboration. Lastly, but by no means least, a special thank you to our CEO, David Vijan, and our Chairperson, Amber D. Scott, for keeping us on our toes and steering the ship with vision and purpose. 

Here’s to 12 years of achievement and to the future.

Securities Dealers See Rising FINTRAC Penalties

We’re seeing FINTRAC ramp up Administrative Monetary Penalties against all sectors, however, for securities dealers we’re starting to see some heavy hits, something we haven’t seen before, signaling a graduated approach to compliance assessments by FINTRAC.

On July 3, 2025, FINTRAC announced an Administrative Monetary Penalty of $544,500 against an investment dealer headquartered in Vancouver, British Columbia. Additionally, on February 13, 2025, FINTRAC announced an Administrative Monetary Penalty of $66,000 against, a Wealth Management Securities Dealer in Ontario.

Securities dealers must fulfill specific obligations as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations, to help combat money laundering and terrorist activity financing in Canada. As defined under the PCMLTFA, a securities dealer means a person or entity authorized under provincial legislation to engage in the business of dealing in securities or any other financial instruments or to provide portfolio management or investment advising services.

FINTRAC has the legislative authority to issue administrative monetary penalties (AMPs) to reporting entities that are found to be non-compliant with the PCMLTFA and associated Regulations. For more information, see Penalties for non-compliance.

Between the two notices, it was found that following compliance examinations, the following failures were found, which resulted in the AMPs:

  • Failure to develop and apply written compliance policies and procedures that are kept up to date; and, in the case of an entity, are approved by a senior officer. Specifically, the firm did not sufficiently develop and document its compliance policies and procedures in relation to know your client and record keeping requirements.
  • Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors. Specifically, the firm’s risk assessment was incomplete, as it did not clearly outline the risks associated with its clients and did not contain assessment of all the required categories. In addition, the risk assessment did not document an adequate methodology for the assessment of its money laundering and terrorist financing risks.
  • Failure to institute and document the prescribed review of its policies and procedures, risk assessment and training program. Specifically, the scope of a review did not cover the firm’s risk assessment. Additionally, the review did not specify how the organization ensured that its compliance program was tested for effectiveness.
  • Failure to submit suspicious transaction reports where there were reasonable grounds to suspect that transactions or attempted transactions were related to a money laundering or terrorist activity financing offence.
  • Failure to take the prescribed special measures for high risk.

Of all the findings, the ones that netted the highest AMP were related specifically to:

  • Failure to submit suspicious transaction reports where there were reasonable grounds to suspect that transactions or attempted transactions were related to a money laundering or terrorist activity financing offence.
  • Failure to take the prescribed special measures for high risk.

Failures in suspicious transaction reporting continue to be a big focus for FINTRAC and a trend with the larger value AMPs that we’ve been seeing.

Securities dealers are responsible for the following requirements under the PCMLTFA and associated Regulations:

  1. Compliance program:
    1. Appoint a compliance officer who is responsible for implementing the program. The Compliance Officer must always have access to management and the authority to carry out their duties.
    2. Develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer. Policies and procedures must be detailed and reflect the reporting entities business model.
    3. Conduct a risk assessment of your business to assess and document the risk of a money laundering or terrorist activity financing offence occurring in the course of your activities. The categories that must be assessed are outlined in guidance.
    4. Develop and maintain a written, ongoing compliance training program for your employees, agents or mandataries, or other authorized persons.
    5. Institute and document a plan for the ongoing compliance training program and deliver the training (training plan).
    6. Institute and document a plan for a review of the compliance program for the purpose of testing its effectiveness, and carry out this review every two years at a minimum (two-year effectiveness review). The review must test all parts of your compliance program as well as operations.
  2. Know your client:
    1. verifying client identity,
    2. politically exposed persons, heads of international organizations, their family members and close associates, beneficial ownership, and
    3. third party determination.
  3. Transaction reporting:
    1. Suspicious Transaction reporting
    2. Listed Person or Entity Property Reports
    3. Large Cash Transactions reporting
    4. Large Virtual Currency Transaction reporting; and
    5. Reporting suspected sanctions evasion.
  4. Record keeping;
  5. Foreign branches, foreign subsidiaries and affiliates; and
  6. Ministerial directives

We’re Here To Help

If you need help in creating or updating your compliance program and processes, are due for a Compliance Effectiveness Review, or have general questions on your compliance obligations,  please get in touch.

What Should You Do After Submitting Suspicious Transaction Reports to FINTRAC?

What Happens After You Submit a Suspicious Transaction Report?

When it comes to AML compliance, submitting a Suspicious Transaction Report (STR) to FINTRAC is just the beginning, not the end.

In this short video presentation, Divya Bhaktha from Outlier Compliance Group breaks down exactly what you need to do after an STR is filed, and the consequences if you don’t follow-up correctly.

Reference Links

Public notice of administrative monetary penalties

Reporting suspicious transactions to FINTRAC

Guide on harm done assessment for suspicious transaction reports violations (section 2.3.4)

 

Need help navigating STR obligations? Email us at info@outliercanada.com or get in touch here.

FINTRAC MSB Registration Renewals

It has come to our attention that FINTRAC may not be sending out reminders to MSBs regarding upcoming renewals of MSB registrations.

Is your MSB registration due for renewal?

You can check the status (and expiry date) of your MSB registration here.

MSB must renew their MSB registration with FINTRAC every two years. We recommend renewing your registration at least one month before the expiration date, as it can take some time for FINTRAC to process the renewal request form. For your reference, keep a copy of the form before you submit.

Once the form is submitted, watch your inbox for additional requests from FINTRAC. We recommend whitelisting *@fintrac-canafe.gc.ca addresses, so that they don’t get caught in your spam filters.

For those who prefer video content, Outlier’s Divya Bhaktha walks through the MSB registration renewal process in this short video — click here to watch.

Need a hand?

If you need assistance with your MSB registration or other compliance matters, please get in touch here, or email us at info@outliercanada.com

Outlier Compliance Group welcomes Daniel Dobre!

The Outlier Compliance Group team is thrilled to welcome our newest member, Daniel Dobre.

Daniel brings a wealth of banking compliance experience, most recently as Director Anti-Money Laundering, Financial Crime Oversight at Royal Bank of Canada.

Daniel’s Bio

Daniel joins the Outlier team with more than 18 years of compliance experience working within the Financial Institution sector. A seasoned professional, Daniel brings a strong background in regulatory compliance and risk expertise. Throughout his career, he has held senior oversight roles in financial crime and regulatory compliance, leading the design and execution of monitoring and testing programs, and developing and enhancing compliance methodologies. His work has included oversight of second line reviews, implementation of AML/ATF systems and processes, execution of risk assessments all with a strong focus on stakeholder engagement, communication and building strong business relationships.

Daniel recognized early in his career that compliance was the path he wanted to pursue. Following a management trainee program that provided exposure to various areas of banking, he chose to join the compliance team, despite strong interest from several other departments. While doing branch compliance reviews for four years, Daniel realized that anti-money laundering is what he is most passionate about and made it his goal to grow in this field. After moving to Canada, Daniel was determined to re-enter the compliance field, which he successfully achieved in 2010. After a few years of growing his experience within compliance, operations, and internal controls, he had the opportunity to join the CAMLO of a financial institution to enhance their AML program following a regulator’s exam. Among his key accomplishments were the successful development and implementation of a real-time customer name screening process, as well as the design and rollout of a transaction monitoring system and an associated alert investigation process. 

Daniel’s passion for financial crime risk led him to join a major bank, where he was able to gain valuable experience while leading, monitoring, and testing reviews over the financial crime risks, controls and associated regulations for all lines of business and functions within the bank. He later spearheaded the design and implementation of an integrated monitoring and testing (assurance) program, covering both financial crime and regulatory compliance risks, while overseeing testing teams across 3 continents. During this time, Daniel also became CAMS and ICA certified, and is looking forward to helping make a difference in the financial crime industry by ensuring that all customers are operating safely and in accordance with the regulatory requirements. 

As with all our consultants, Daniel has deep subject matter expertise and supports Outlier’s mission statement “good compliance can enable good business”. He is passionate about compliance and risk management, and believes that businesses can be successful and compliant at the same time.

Please join us in welcoming Daniel!

He’ll be attending the Futurist conference in Toronto as his first official Outlier event coming up on May 13, 2025. Please say hello and welcome him to the team.

Outlier Team Update: Promoting Suzie Fernandes

The Outlier team is thrilled to announce that Suzie Fernandes has been promoted to the position of Chief of Staff. 

Suzie joined the Outlier team in 2018. Her ability to be meticulously organized has played a key role in our growth. Her knack for analyzing situations and determining what’s needed to keep the Outlier team moving forward has us excited about her having a more hands-on role in the company maintaining many of our day-to-day operations.

Please join us in congratulating Suzie on her promotion and wishing her well in her new role.

 

 

From the new CEO, David Vijan

Firstly, I want to thank Amber for all the work she has done as Outlier Compliance Group’s CEO for the past 11 years. Outlier Compliance Group is different from other consulting firms which is a testament to her leadership over the years. Amber may be taking time to enjoy other things in life but she will remain with the Outlier team as Chairperson and Strategic Advisor.

This part of the transition delights me to no end. Although I bring almost 20 years of my own compliance and leadership experience, growing, scaling, and professionalizing compliance teams, I truly believe that you only get to the next horizon by collaborating and having the support of the people who got you this far. Knowing that Amber will continue to be a part of the Outlier family is a great comfort.

For our clients, I want to assure you that not much will change. Outlier Compliance Group will continue to be the company where our core staff members have at least 10,000 hours (and often more than a decade) of in-house compliance experience, and we will still be the company that believes good compliance is good business. I may be stepping into the role of CEO but our services are and will remain a team effort. As always, we are committed to providing you with top tier compliance support and we appreciate your business.

As the Canadian regulatory environment becomes more complicated, we will continue to help companies in both established and emerging sectors navigate increasingly complex Canadian regulatory requirements. Our clients range from startups just beginning their compliance journey to large firms looking to elevate their compliance systems to meet an evolving regulatory landscape. As such, we will be looking to offer expanded services, some of which will be formed via strategic partnerships, where it makes sense for our clients’ needs. Stay-tuned for more on that front in the near future. 

I look forward to working with you on your compliance journey and welcome any questions or concerns. Feel free to reach out directly via email to info@outliercanada.com

From the outgoing CEO and incoming Chairperson, Amber D. Scott

When Outlier Solutions Inc. (Outlier Compliance Group) launched in 2013, the business model was relatively novel: a consulting firm made up exclusively of highly-experienced compliance professionals with deep in-house compliance experience. The firm took its name from Malcolm Gladwell’s Book, “Outliers, the Story of Success,” which espoused the notion that to be truly proficient in a skill, 10,000 hours of practice is required. 

That was the bar that was set, met, and most often exceeded by every compliance professional that joined our team over the years. I am very fortunate to have in David Vijan a co-founder and colleague with experience in growing, scaling, and professionalising compliance teams. As of today, David will be officially taking over as CEO of Outlier Solutions Inc.

I cannot imagine anyone more qualified than David to take the business and the team forward. While I will be stepping back from most day-to-day functions, I will remain a strategic advisor to Outlier, and the Chairperson of the Board.  

As I transition into my new role, I can’t help but reflect on the Outlier journey that started over a decade ago. At the beginning, the goal was nothing short of changing the face of consulting. 

I was frustrated with the “leverage model”. This model is used by the big accounting and consulting firms that throw bodies, often junior with little in-house experience, at a problem in the hopes of resolving it, thereby “leveraging” the team members for this purpose. I wanted to do something that was different, not only in terms of the skills of their consultants, but in every aspect of corporate life: from compensation to leadership.

This was not simply hubris on my part, though I’m sure there was a healthy dash of that as well. I wanted to build the types of services that I wished I had access to when I was a Compliance Officer working in-house. 

A wide range of concepts fell under this umbrella, from practical advice on operational compliance, to true fixed-fee services (because no one likes surprise invoices!) It also includes online tools accessible to small businesses that may not be able to pay for consulting services but still have compliance obligations to meet. 

The goal was always to build solutions that would provide excellent value to Canadian businesses, large and small, from coast to coast to coast. My experience at Outlier has exceeded my wildest expectations. If I could go back in time and give a piece of advice to myself as a new entrepreneur, I would tell myself to think bigger!

The week that Outlier was formed, one of my mentors, Michelle McCarthy, asked me if I had thought about what my exit would look like. I hadn’t, and didn’t want to pay that much mind, as I was hyper focussed on solving more immediate problems. 

I told her that I wanted to create something that would not only function but excel without me. I wanted a team of professionals with skills that exceed my own and who would carry the work forward in ways that had not yet occurred to me. I wasn’t thinking about it at the time, but I am now reminded of how one of my favourite business books, Good to Great, emphasises the importance of having the right people in place and the success of internally promoted CEOs. 

My eternal support for and commitment to David, the Outlier team, our clients, and strategic partners is unwaveringly strong. I can say that there is not a doubt in my mind that the Outlier team is the best compliance consulting team in Canada, and I am excited to see how the vision that began over a decade ago continues to grow and expand.

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