How often must the PCMLTFA compliance policies be reviewed to test their effectiveness?

• A. Every 5 years
• B. Every 2 years
• C. Every year
• D. Never

Answer: (B)

Regular review of PCMLTFA compliance policies is essential to ensure the controls stay aligned with current risks and regulatory requirements. Testing their effectiveness means checking whether the policies actually work in practice—do the client identification procedures, record-keeping, reporting, and monitoring steps catch and deter money laundering and terrorist financing as intended?

The required cadence is every two years. This biennial cycle provides a workable interval to assess whether the controls are still effective amid evolving threats and possible changes in business operations or regulations. If gaps are found or if there are significant changes (like new products, services, or guidance from FINTRAC), updates should be made promptly. While the formal policy review occurs on a two-year schedule, ad hoc reviews can occur sooner in response to material changes to ensure ongoing effectiveness.