AML | Outlier Solutions

The theme of GFF 2026 – “Potential to Impact: Agentic AI, Tokenization, Quantum — Trusted, Connected, Global Systems for Inclusive Finance” reflects a defining phase in global banking, where emerging technologies are reshaping financial systems and creating new opportunities for innovation and collaboration. The dialogue will bring together leaders from the fintech, banking, regulatory, and technology sectors to discuss emerging trends in financial services and explore opportunities for collaboration between India, Canada, and the global fintech ecosystem.

Join Outlier’s Dr. Amber D. Scott in moderating a fireside chat with the Bank of Canada’s Managing Director of Supervision, Anne Butler.

Date: July 15, 2026

Time: TBD

Register here.

Join the module 5 discussion on Technology and Industry Disruptors as part of The Osgoode Certificate in Regulatory Compliance & Legal Risk Management for Financial Institutions, offered by Osgoode Professional Development at York University. Specifically, in Part B: Bitcoin/Blockchain and Case Studies, Outlier‘s Amber Scott will explore how blockchain technology and cryptocurrencies are reshaping the financial services landscape and challenging traditional regulatory frameworks.

Overall, the session will examine the opportunities, risks, and compliance implications associated with digital assets, decentralized technologies, and emerging business models.

For more information and to register, click here.

The Outlier Compliance Group team is thrilled to welcome two of our newest members, Jasbir Dhillon and Wioletta Traynor.

Jasbir brings deep money services business (MSB) and real estate experience to the team, and Wioletta brings deep jewelry sector expertise and is a CPA.

Jasbir’s Bio

Jasbir is a compliance and financial crime professional with over 15 years of experience in regulatory oversight, anti-money laundering (AML), and risk management across the banking, money services business, and consulting sectors. She has extensive experience supporting organizations in meeting their obligations under Canadian regulatory frameworks, including FINTRAC requirements, the PCMLTFA, and PIPEDA.

Her work focuses on regulatory audits, AML/ATF investigations, risk assessments, and the development of robust compliance programs that help organizations navigate complex regulatory environments while maintaining strong operational integrity.

Wioletta’s Bio

Wioletta Traynor, CPA, CGA brings more than 13 years of leadership experience in the precious metals, e-commerce industry, with a background in AML/ATF compliance, risk and finance management, and private accounting.

Prior to joining Outlier Solutions Inc., Wioletta has served in a senior leadership role, including Chief Deputy Compliance Officer, Financial Controller, and CFO, helping businesses with compliance and accounting frameworks, internal controls, and internal compliance systems and investigations. Her experience includes AML/ATF Compliance Effectiveness Reviews, GAP Analysis, policy development, AML/ATF risk assessments, internal investigations, fraud prevention, and general compliance.

Over the years, she has contributed to multiple fraud related investigations involving suspicious transactions and financial misconduct, including the widely publicized Project Bridle Path mortgage fraud case.

Wioletta is passionate about helping organizations go beyond the “tick box” AML/ATF checklist and building effective programs to protect businesses from financial and reputational risk.

Please join us in welcoming Jasbir and Wioletta!

As with all our consultants, both Jasbir and Wioletta have deep subject matter expertise of more than 10,000 hours and support Outlier’s mission statement “good compliance can enable good business”.

FinteQC brings together researchers, graduate students, and industry practitioners to examine emerging ideas and advance the field of financial technology. Additionally, the conference features rigorous scholarship, sparks sharp debate, and drives real-world impact.

As part of this year’s program, join Outlier’s Divya Bhaktha for a panel discussion on fintech and legacy regulatory systems. Together, she and fellow panelists will explore how innovation interacts with established regulatory frameworks—and what that means for the future of finance.

If you searched for “Outlier AI” and ended up here, you’re not alone – but you are in the wrong place.

Outlier Solutions Inc. (operating as Outlier Compliance Group) is a Canadian compliance consulting firm based in Canada. We help reporting entities navigate their regulatory obligations under Canadian financial compliance frameworks. We are not affiliated with, related to, or connected to Outlier AI in any way.

So What is Outlier AI?

Outlier AI is a separate company. Any inquiries meant for them should be directed through their own website. Contacting us will not reach them – we have no way to forward messages or act on their behalf.

Why the Confusion?

The similarity in our names has led to a growing number of misdirected inquiries, particularly as AI companies have expanded rapidly in recent years. If you’re looking for Outlier AI specifically, please visit their website directly.

Now, if You’re in the Right Place…

If you’re a reporting entity looking for compliance support — whether that’s AML, regulatory risk, or compliance program development — we’re here to help. Please get in touch.

Canada’s anti-money laundering landscape is undergoing its most significant transformation in years, and compliance professionals need to be ready.

Outlier’s Co-Founder & CEO, David Vijan, will join industry leaders at Infonex’s Financial Services Regulation 2026 conference to unpack the sweeping changes brought by Bill C-12 — the Strengthening Canada’s Immigration System and Borders Act — which received Royal Assent on March 26, 2026. The legislation dramatically raises the stakes for AML compliance, increasing administrative monetary penalties by up to 40 times current levels, expanding mandatory compliance agreements with FINTRAC, and broadening registration requirements to all reporting entities under the PCMLTFA.

David will also address the Government of Canada’s plans to establish a new Financial Crimes Agency — designed to serve as Canada’s lead enforcement authority on money laundering, organized crime, and online financial fraud — and what it means for financial institutions preparing for a new era of oversight.

Attendees will leave with a clearer picture of what these legislative and structural changes mean in practice, and how organizations can strengthen their AML programs to meet rising regulatory expectations.

For more information and to register, click here.

Have you completed your annual AML Training? Jewellers are required to conduct Anti-Money Laundering (AML) Compliance training for staff annually.

Join Outlier Compliance Group‘s CEO and AML Expert, David Vijan, for CJA‘s annual “AML 101 For Jewellers” webinar. This webinar focuses on AML basics and can be used as part of your mandatory annual training, in addition to advising your staff on your own specific procedures. Case studies and key updates shared during the webinar will assist attendees with their compliance obligations.

Register here.

Date & Time: April 27, 2026 – 1:00 pm – 2:00 pm (ET)

Explore the latest developments shaping the compliance landscape at CMSBA 2026. This year’s program features expert-led sessions covering key regulatory updates, emerging risks, and practical strategies for MSBs and financial professionals.

Topics will include recent amendments to the PCMLTFA and evolving FINTRAC reporting expectations, as well as guidance on RPAA and it’s associated regulations, and preparing for initial supervisory reviews. Furthermore, attendees will gain insights into reporting best practices, including STRs, LPEPRs, AMPs highlights, and common pitfalls to avoid.

The agenda will also dive into emerging fraud typologies, crypto-related misuse, scams, and cybercrime trends impacting the industry. Sessions on AI and automation in AML will showcase real-world applications across KYC, KYB, transaction monitoring, and remediation.

Join Amber Scott as a panelist at CMSBA 2026, exploring best practices for hiring a qualified Chief Anti-Money Laundering Officer (CAMLO). Also, don’t miss Divya Bhaktha in the discussion of compliance programs aimed at preventing issues leading to recent AMPs.

Background

Under the RPAA and the Retail Payment Activities Regulations (RPAR), Payment service providers (PSPs) must submit an annual report through the Bank of Canada’s (BoC) online portal using the prescribed reporting form. Reports must be filed annually by March 31 and must cover retail payment activities conducted during the prior calendar year.

Who Must Comply

All PSPs that are on the registration list with BoC must complete the annual report. For clarity, BoC has established the following deadlines:

PSPs registered before March 9, 2026, must submit their report by March 31, 2026.
PSPs registered between March 9 and March 30, 2026, have until April 28, 2026.

PSPs on the application list as of March 31, 2026, are not required to file a report for the 2025 year and will report in 2026.

The annual report is now available through PSP Connect. It includes mandatory sections and does not permit structural or formatting changes. It is set up similarly to what PSPs saw as part of registration. All required fields must be completed, and any omissions must be explained in accordance with BoC guidance.

What to Report

The following are the reporting elements of the annual report.

1. Operational Risk and Incident Management

In this section, PSPs must provide information on the governance, design, and effectiveness of their operational risk management and incident response frameworks. This includes confirming whether the framework, and any material updates to it, were approved during the reporting year by the senior officer.

In this section, PSPs must identify the operational risk categories monitored during the year and must outline what protective and detective measures were in place. Importantly, this action requires PSPs to provide quantitative staffing and resourcing information.

PSPs must also explain how operational risks arising from third-party service providers and agents or mandataries are managed. PSPs must also indicate whether agreements with third-party service providers were entered into, amended, extended, or renewed. Where agents or mandataries are used, PSPs are expected to confirm that responsibilities are clearly defined, operational risk criteria are established, and assessments are performed to evaluate whether those criteria are met.

Some key requirements for this section are:

Did the PSP classify assets and business processes by sensitivity and criticality?
Were sufficient human and financial resources available to implement and maintain the framework?
Did the framework set out operational reliability objectives, targets, and indicators?
Which measures were in place to mitigate technology risks and protect assets and processes?
Did the framework include incident response and recovery plans, including third-party incidents?
Which elements were included in the incident response plan?

2. Safeguarding of End-User Funds

In this section, PSPs that perform the payment function of holding funds on behalf of end-users must identify whether they safeguard funds through a trust account or through an account supported by insurance or a guarantee, and whether the safeguarding method changed during the reporting year.

PSPs must report whether end-user funds are placed into a safeguarding account upon receipt and, where processing constraints exist, whether funds are placed into the safeguarding account by the next business day. PSPs must identify whether safeguarding accounts are held with Canadian or foreign financial institutions and, where applicable, identify those institutions and their regulators.

PSPs must describe the liquidity approach used to ensure end-users have reliable access to their funds and outline the procedures in place for returning those funds in the event of the PSP’s insolvency.

Some key requirements for this section relate to shortfall reporting. PSPs must report instances during the reporting year where safeguarded funds were insufficient, including:

the date the shortfall occurred and the date it was resolved,
the maximum daily shortfall amount (in CAD),
the root cause (selected from prescribed categories), and
the measures taken to prevent recurrence.

3. Significant Changes and Incidents

In this section, PSPs must identify all significant changes that occurred during the reporting year. A change is considered significant where it could reasonably be expected to materially affect operational risk or the safeguarding of end-user funds. The annual report requires each change to be reported separately, including the month and year in which the change took effect.

Examples of reportable significant changes include new or amended outsourcing arrangements, changes to third-party service provider relationships, material technology changes, geographic expansions, new products or market segments, changes in participation in payment systems, and material changes to organizational structure or staffing levels.

It is important to note that the report must also include a complete inventory of incidents experienced during the year, including incidents that were not required to be reported to the Bank under the RPAA at the time they occurred.

PSPs must also identify any retail payment activities that the PSP began or ceased to perform during the reporting year.

4. Ubiquity and Interconnectedness Metrics

In this section, PSPs must provide quantitative metrics as it relates to end-user funds used by the Bank to assess a PSP’s footprint and interconnectedness within the Canadian payments ecosystem.

These metrics must capture transactions where the PSP performed a payment function directly or indirectly, and must be reported separately for all end-users and end-users in Canada, where applicable.

PSPs must also report the total number of distinct end-users served during the reporting year, including users receiving services directly and indirectly, and provide information on services performed for other registered PSPs.

Some key metrics that must be reported include:

Value of End-User Funds Held

The maximum Canadian Dollar (CAD) equivalent value of end-user funds held at any time during the year.
For each month, report the average daily value (in CAD) at month-end.
Both the total of all funds held, and a breakdown by currency held.

End-Users

Total number of distinct end-users, and
Number of users receiving direct vs. indirect services (via third-party PSPs).

Number and Value of Electronic Funds Transfers (EFTs)

Monthly Count and Total Value
- Report the monthly count and total value of EFTs.
- Values in CAD (as both a total of all currencies combined, and a breakdown by currency of the EFT).
Value by Payment Type
- Report an estimate of the total value of EFTs by payment type as a share of total value.

PSP with a place of business in Canada must report values for end-users in Canada and end-users outside of Canada as separate amounts.

5. Financial Information

In this section, PSPs must report key financial information, including total revenue, operating expenses, and total equity. Financial information may be reported using the PSP’s fiscal year-end, whereas most other reporting elements must align with the calendar year.

6. Record-Keeping

In this section, PSPs must confirm whether they maintain records sufficient to demonstrate compliance with the RPAA and the Retail Payment Activities Regulations. PSPs must indicate whether record-keeping is complete, partially complete, or not in place, and should be prepared to support these responses if requested by the Bank.

Preparing for Report

The annual reporting form is available through PSP Connect as of February 2, 2026. We suggest that PSPs may begin gathering the needed information for submission at any time prior to the applicable deadline. To help make this a bit easier, Outlier has put together a spreadsheet that will help in compiling the needed information. Please note that this spreadsheet does not replace formal BoC guidance. The system does allow organizations to save and continue where you left off.

Anti-Money Laundering
Consulting Services & Strategies

GFF26 Global Connect – Canada

Osgoode Certificate in Regulatory Compliance & Legal Risk Management for Financial Institutions

Outlier Compliance Group welcomes Jasbir Dhillon and Wioletta Traynor!

Jasbir’s Bio

Wioletta’s Bio

Please join us in welcoming Jasbir and Wioletta!

FinteQC 2026

Looking for Outlier AI? You’ve Reached the Wrong Company

So What is Outlier AI?

Why the Confusion?

Now, if You’re in the Right Place…

Infonex – Financial Services Regulation 2026 (Virtual)

AML 101 for Jewellers Webinar

Canadian MSB Association: 2026 Spring Conference

RPAA Annual Reporting – Reminder and Key Requirements