Outlier Compliance Group

Outlier Compliance Group Outlier specializes in Anti-Money Laundering (AML), Sanctions, Privacy, Regulatory Compliance, Retail Payment Compliance & Pan Canadian Trust Framework (PCTF).

Outlier is a group of affiliated compliance consulting firms that share core values, and the ability to form international teams with local expertise. In his analysis of success, Outliers, Malcolm Gladwell notes that one must generally practice for 10,000 hours to truly master a skill. We believe that this is true of compliance consulting. We strive to be experts that collaborate in order to bring

the best products and services to our clients. Outlier Solutions’ expert compliance consultants (a.k.a. compliance ninjas) specialize in:

- Anti Money Laundering (AML),
- Counter Terrorist Financing (CTF),
- Bank Secrecy Act (BSA),
- Foreign Account Tax Compliance Act (FATCA),
-Privacy,
- Regulatory Compliance,
- Corporate Governance,
- Policy & Procedure development,
- Risk Assessment & Gap Analysis,
- Independent Compliance Effectiveness Reviews,
- FCA API and EMI license application assistance,
- Preparation and implementation assistance with post-examination action plans including lookback support, and
- Interim MLRO, CAMLO & Head of Compliance support. Outlier Solutions partners are not law firms, although we collaborate with local law firms for specific projects. We are happy to recommend local law firms and other practitioners where we are not able to offer appropriate consulting services directly. If you would like to speak with us about an upcoming compliance consulting project, please contact us. Core Values:

-We are compliance experts and entrepreneurs.
-We stand by our work and strive for continuous improvement.
-We leave our egos at home, making room for us to focus fully on your project.
-We pay attention to your business goals, to make recommendations that fit.
-We believe that good compliance is good business. Find an Outlier:

International: www.outlierinternational.com
Canada: www.outliercanada.com
Europe: www.outliercompliance.com
USA: www.outlierusa.com

06/02/2026

Screened your customer at onboarding? Great. That covers part of your sanctions screening obligation.

Outlier's Daniel Dobre breaks down the three moments when screening is required, and the one that most firms aren't doing consistently.

Onboarding is covered. Ongoing risk-based KYC is usually on the radar. But monitoring government sanctions list updates and rescreening when they change? That one slips through the cracks more often than it should.

A quick registration for government notifications fixes that. No excuse not to.

☕ Catch this week's Weekly Cup of Compliance below.

05/26/2026

FINTRAC's penalty process used to follow a set sequence. Under the updated framework, that sequence no longer applies.

In this week's Weekly Cup of Compliance, Outlier's David Vijan explains how FINTRAC can now issue an Administrative Monetary Penalty at any stage based solely on the information they have at that point, without requiring a full examination first.

What used to be a linear path from self-attestation to examination to fine is now a much more flexible process for the regulator.

Early-stage interactions with FINTRAC carry more weight than they used to. Treat them accordingly.

☕ Catch this week's Weekly Cup of Compliance below.

05/19/2026

Filing your fifth STR on the same client this month due to continued behaviour? The reports are required. The relationship, though, is worth reconsidering.

Divya Bhaktha breaks down what firms should be thinking about when suspicious activity just keeps coming from the same source.

There's no rule against filing as many SSTRs as needed. But at some point the volume itself is telling you something. Some firms draw the line at three. Others factor in risk appetite. Either way, having no policy at all is its own kind of risk.

Report every instance. But also ask whether you should still be in the relationship at all.

☕ Catch this week's Weekly Cup of Compliance below.

05/12/2026

When you respond to a FINTRAC assessment, that data doesn't just disappear.

Outlier's David Vijan explains what FINTRAC actually does with the information collected through its assessment tools, and why it matters for your firm.

The data is used to evaluate risk profiles and determine which companies get selected for a formal examination. It's also used to identify sector-wide gaps and inform future regulatory guidance.

Your submission shapes how the regulator sees you. That's worth taking seriously.

☕ Catch this week's Weekly Cup of Compliance below.

05/05/2026

For new regulated entities, building a Risk Assessment is required. Building a good one is where the real challenge starts.

In this week's Weekly Cup of Compliance, Daniel Dobre explains why smaller firms especially should seek expert input early, and why getting the foundation right matters more than simply having a document ready for FINTRAC.

A risk assessment needs to reflect your specific business, not just check a box. And since it has to be updated annually, a weak foundation makes every future update harder than it needs to be.

Do it right the first time. It pays off every year after.

☕ Catch this week's Weekly Cup of Compliance below.

04/28/2026

Rushing through a FINTRAC questionnaire? That could carry serious risks.

Outlier's Co-Founder and CEO, David Vijan, breaks down why these assessments deserve more attention than most firms give them. Handle one poorly and you're looking at a potential AMP. Handle it really poorly and you may be inviting a full FINTRAC examination. A casino in 2025 learned this the hard way.

Assessments are not warm-up exercises. They count.

☕ Catch this week's Weekly Cup of Compliance below.

04/21/2026

Good news: you filed your STR. Bad news: that doesn't always mean you're done.

In this week's Weekly Cup of Compliance, Outlier's Divya Bhaktha breaks down the threshold for a Subsequent Suspicious Transaction Report (SSTR), and why "we already reported that account" is not the compliance shield some teams think it is.
The bar for filing an SSTR is identical to the original STR. If the suspicion is still there and new activity has occurred, a new report is required.

New activity. Same suspicion. New report. That's the obligation.

☕ Catch this week's Weekly Cup of Compliance below.

04/14/2026

A compliance program is only as strong as the risk assessment behind it.

In this week's Weekly Cup of Compliance, Outlier's Daniel Dobre explains why risk assessments are the most critical element of any AML program, and why treating them as a once-a-year obligation misses the point.

Business-wide assessments have an annual requirement. But relationship-based assessments tied to specific customers need to move with the customer's activity, not on a fixed schedule. When a customer's behaviour shifts, their risk rating should too.

The best programs don't just meet the standard. They stay ahead of it.

☕ Catch this week's Weekly Cup of Compliance below.

04/07/2026

Talking to FINTRAC doesn't have to feel like walking a tightrope.

Outlier's Co-Founder and CEO, David Vijan, breaks down when it makes sense to bring in a legal expert or consultant when responding to FINTRAC assessment tools. The core message? Transparency matters. But so does how you say things. Regulators aren't trying to trip you up, but miscommunication can make it feel that way. A consultant helps make sure your intended message is actually the message that lands.

If you're unsure about a requirement or your own internal process, that's exactly the moment to ask for help.

☕ Catch this week's Weekly Cup of Compliance below.

Address

120 Adelaide Street W. , Suite 2500
Toronto, ON
M5H1T1

Opening Hours

Monday 9am - 5pm
Tuesday 9am - 5pm
Wednesday 9am - 5pm
Thursday 9am - 5pm
Friday 9am - 5pm

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