PCMLTFA requires a brokerage to maintain five specific written documents. The Written Policies card, in the Policies section of the Setup tab on Brokerage Compliance, is where you upload each one as a PDF or link to a living version, and it's the same card the compliance setup wizard shows you during onboarding.
When You'd Use This
Fill this in during compliance setup if you have your documents ready, or come back to it any time afterward. It also matters when a regulator asks for your program package: a document that's still empty here has nothing to send.
The Five Documents
Each of the five is tracked independently, so replacing one never touches the others:
- Compliance program: your master written program, required to exist at all times under PCMLTFA s.9.6.
- Policies & procedures: your operational rules for KYC, EDD triggers, and suspicious transaction reporting decisions.
- Risk methodology: how you assess and rate client, geography, product, and transaction risk.
- Training curriculum: the master curriculum every AML training completion is measured against.
- Biennial effectiveness review: the template an independent reviewer audits your program against every two years.
Uploading or Linking a Document
- Find the document's row and either drag a PDF onto it or select it to browse.
- Or select Paste link and enter an
https://URL to a living document, such as a Notion page or Google Doc, instead of uploading a file.
A file must be a PDF under 50MB. A file and a link are mutually exclusive per document: saving one clears the other, so you always have exactly one version on record, not two that can drift apart. Selecting an uploaded document opens a preview; selecting a linked one opens it in a new tab.
An empty document is a gap, not a placeholder
Nothing in BrokerPlus requires these five to be filled in before the rest of the program activates. A brokerage can finish setup, run screenings, and operate normally with one or more of these sitting empty, and be out of compliance without any warning telling them so.
Skipping One for Now
In the setup wizard, this step is explicitly optional: you can select Continue without uploading anything and finish setup. In the standing Policies section, an empty row just shows its description as a prompt rather than blocking anything else on the page. If you don't have a document yet, both the wizard and the card link out to FINTRAC's own compliance program guidance to help you build one.
Replacing a Document
Uploading a new PDF or saving a new link replaces whatever was there before; the prior file is removed from storage rather than kept as a version history. Select the X on a filled row to clear it back to empty instead.
Setting Your Next Effectiveness Review
Your program record also tracks a due date for your next effectiveness review, separate from the review document itself. There's no dedicated field for it on this card yet; ask the assistant to set or update the date, and it's saved on your program record alongside everything else here.
What to Do Next
- What Your Compliance Program Covers to see how these documents fit into the rest of setup.
- Produce Your Program Package for a Regulator once these five are filled in and you need to hand them over.
- Assign Compliance Reviewers so someone besides you can keep these current.