Which of the following is NOT an element of a PCMLTFA compliance program?

• A. Appointment of a compliance officer.
• B. Written on-going training program for all employees.
• C. Documentation and maintenance of policies and procedures.
• D. Public posting of client details.

Answer: (D)

A PCMLTFA compliance program centers on governance, training, and documented procedures to prevent money laundering and financing of terrorism. Appointing a compliance officer creates accountability and a dedicated resource to oversee AML/CTF efforts. A written on-going training program for all employees ensures everyone understands obligations, red flags, and how to report suspicious activity. Documentation and maintenance of policies and procedures provides a standardized, auditable framework that guides staff actions and keeps the program up to date.

Public posting of client details, on the other hand, would expose sensitive information and violate privacy protections. It is not something a PCMLTFA compliance program would require or permit, and it undermines the safeguards the program is meant to establish.