Canada keeps widening the net of businesses required to run anti-money laundering programs, and since March 2026 the penalties for getting it wrong have increased as much as fortyfold. A boutique Toronto consultancy has built its practice entirely around that problem.
A Compliance Obligation Many Owners Do Not Know They Have
Canada’s anti-money laundering framework reaches far further than most business owners assume. It covers banks and credit unions, but also money services businesses, including cryptocurrency dealers and many payment firms, as well as real estate brokers and agents and dealers in precious metals and stones. Since April 1, 2025, factoring companies, cheque cashing businesses, and financing and leasing entities have also been brought within scope.
If a business is a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, it must appoint a compliance officer, maintain written compliance policies and procedures, assess and document its money laundering and terrorist financing risks, conduct client due diligence, keep prescribed records, train staff, file reports, and have the effectiveness of its program reviewed at least every two years. The Financial Transactions and Reports Analysis Centre of Canada, FINTRAC, examines those programs and can impose administrative monetary penalties when they fall short.
C&G Professional Services Inc. is a Toronto-based boutique consultancy built entirely around this work. It describes itself as a Canadian incorporated firm, fully Canadian-owned and operated, and independent of any global parent or franchise network.
A Founder Who Has Worked Both Sides
“Since March, a compliance program that exists only on paper is a very serious violation under the law. Most of the businesses we see are not trying to cut corners. They are simply built for registration, not for examination. Our job is to close that gap before FINTRAC finds it.” – Otegbade, O.C.
Claudius O. Otegbade is co-founder and lead partner. His credentials are unusually dense for a boutique practice: CPA (New York), FCA (Nigeria), MBA, and certifications including CAMS, CFCS, CFE, CFI, CBP, CCI and CIPP/C, with close to two decades across anti-money laundering compliance, forensic accounting, fraud investigation and regulatory audit.
The career path behind those letters matters more than the letters. He began as an auditor with PKF International and worked as a forensic auditor across several consulting firms, including work in Nigeria’s oil and gas sector. He then spent five years in anti-money laundering at Grant Thornton LLP and MNP LLP, two of Canada’s larger accounting firms. Before co-founding C&G, he served as Director and Chief Compliance Officer at WFCU Credit Union in Ontario, meaning he personally held the role a reporting entity must appoint and carried the accountability that comes with it.
He has also consulted for municipal law enforcement and legal counsel on investigations, is a frequent speaker, and was a founding board member of the Toronto chapter of the Association of Certified Financial Crime Specialists. The firm says its team collectively has more than 40 years of financial crime experience.
The Full Regulatory Life Cycle
The practice covers the sequence a regulated business actually moves through. At the outset, it handles registration, including money services business registration with FINTRAC and payment service provider registration with the Bank of Canada under the Retail Payment Activities Act. It then develops and implements compliance programs, conducts the independent effectiveness reviews the regulations require, and provides training.
When an examination notice arrives, it provides examination assistance. When something has already gone wrong, it handles remediation and lookback work. Alongside the compliance practice sits a forensic capability covering fraud investigation, asset tracing, financial crime analysis and litigation support.
The firm is specific about what its payments work involves, noting that the Bank of Canada expects considerably more than a registration under the Retail Payment Activities Act. It builds the operational risk and incident management framework, the workflow for notifying the Bank of material incidents within the 48-hour deadline, controls for safeguarding end-user funds, and the annual report, and offers to operate them on an ongoing basis.
Positioning Against the Large Firms
The firm competes directly with the anti-money laundering practices of major accounting firms, and its founder has worked inside two of them. Its stated differentiators follow logically from that. Every engagement is led and signed off by a senior professional. As a boutique, it can mobilize without internal approval layers, which matters when an examination notice lands or fraud is discovered. Anti-financial crime is the entire practice, not one department among many.
The firm also emphasizes that compliance programs must be operable. Its stated aim is to produce programs built to be used by real teams rather than documentation that satisfies an auditor and then sits unread. That distinction now carries a price tag.
“Since March, a compliance program that exists only on paper is a very serious violation under the law,” says Otegbade. “Most of the businesses we see are not trying to cut corners. They built them simply for registration, not for examination. Our job is to close that gap before FINTRAC finds it.”
Its reach extends beyond Canada, with advisory work spanning Canadian, United States and African regulatory environments for businesses with cross-border exposure. In 2026, Digital Reference featured the firm and its founder as one of Canada’s leading anti-money laundering consulting firms.
Free Training as a Public Contribution
One element deserves particular mention. C&G publishes two free interactive online courses covering Canada’s anti-money laundering and anti-terrorist financing framework, FINTRAC obligations, client due diligence, reporting and red flags. One is a general program for money services businesses; the other is specific to dealers in precious metals and stones.
For a small reporting entity, mandatory staff training is a real obligation with a real cost, and free sector-specific courses from a practising firm are a genuine contribution. They also function as sensible business development, since the owner who completes the training is the owner who understands what else the regulations require. The course concludes with a certificate of completion.
A Tightening Environment
Canadian anti-money laundering regulation is moving toward a wider scope and firmer enforcement. Successive amendments have brought new sectors within the framework, and the Retail Payment Activities Act has created a new supervisory relationship with the Bank of Canada for payment service providers.
The sharpest change came on March 26, 2026, when Bill C-12 received Royal Assent. Maximum penalties rose fortyfold, to $40,000 for minor violations, $4 million for serious violations and $20 million for very serious ones. Failures in the compliance program itself, including the risk assessment and effectiveness review, now fall in the very serious category, and businesses penalized for prescribed violations must enter mandatory compliance agreements with FINTRAC.
For owners in any affected sector, the practical point is that compliance obligations follow the business model rather than the company’s size. A newly registered fintech or a small precious metals dealer carries obligations that look structurally similar to those of a chartered bank, without the compliance department to meet them. That gap is precisely where a boutique specialist practice earns its place.
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Disclaimer: This article is based on publicly available information intended only for informational purposes. CanadianSME Small Business Magazine does not endorse or guarantee any products or services mentioned. Readers are advised to conduct their research and due diligence before making business decisions.
