About the Company

We are a Toronto-based precious metals and polymetal company engaged in the sourcing, processing, refining, purchasing, sale and international trading of precious metals and mineral products.

As we expand our Canadian and international operations, we are seeking an experienced Compliance Officer / Manager to establish, manage and continuously improve our regulatory compliance, Anti-Money Laundering (AML), Anti-Terrorist Financing (ATF), Know Your Customer (KYC), sanctions and transaction-monitoring framework.

This is a key position with significant responsibility for protecting the company from financial crime, regulatory, reputational and counterparty risks.

Position Overview

The Compliance Officer / Manager will be responsible for overseeing the company's compliance program and ensuring that our activities are conducted in accordance with applicable Canadian laws, regulations, regulatory expectations and internal policies.

The successful candidate will have strong knowledge of FINTRAC requirements, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), AML/ATF controls, KYC/KYB, beneficial ownership, sanctions screening and enhanced due diligence, preferably within precious metals, mining, commodities, financial services or international trading.

The individual will have authority to escalate, delay or recommend the rejection of transactions or business relationships where compliance requirements have not been satisfied or where material risk concerns exist.

Key Responsibilities

1. FINTRAC & AML Compliance

- Serve as the company's designated Compliance Officer and primary internal subject-matter expert for FINTRAC and AML/ATF matters.
- Develop, implement and maintain the company's FINTRAC compliance program.
- Ensure compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.
- Maintain current written compliance policies, procedures and internal controls.
- Monitor regulatory developments and update company policies and procedures accordingly.
- Coordinate responses to FINTRAC inquiries, examinations and information requests.
- Ensure required regulatory reports are accurately prepared, reviewed and submitted within applicable timelines.
- Maintain appropriate compliance records and documentation.

FINTRAC identifies dealers in precious metals and precious stones as reporting entities subject to specific obligations, including compliance programs, client identification, ongoing monitoring, beneficial ownership, PEP/HIO determinations, suspicious transaction reporting and applicable large cash transaction reporting.

2. KYC / KYB / Customer Due Diligence

Develop and oversee a robust Know Your Customer (KYC) and Know Your Business (KYB) program covering customers, suppliers, counterparties, brokers, agents and other relevant business relationships.

Responsibilities include:

- Verifying individual and corporate identities.
- Conducting corporate registry and ownership checks.
- Identifying and verifying beneficial owners.
- Understanding the nature and purpose of the business relationship.
- Reviewing expected transaction activity.
- Assessing customer and counterparty risk.
- Performing enhanced due diligence on higher-risk relationships.
- Maintaining complete and auditable customer files.
- Establishing procedures for periodic KYC refreshes and ongoing monitoring.

3. Source of Funds / Source of Wealth

Establish and administer procedures for determining and documenting:

- Source of funds.
- Source of wealth.
- Origin of precious metals and mineral products where appropriate.
- Ownership and control of counterparties.
- Commercial rationale for significant transactions.
- Supporting documentation for higher-risk transactions.

The Compliance Officer will ensure that the company does not proceed with transactions where required information cannot be satisfactorily established or where identified risks cannot be appropriately mitigated.

4. Precious Metals & Commodity Transaction Compliance

Develop compliance controls specifically suited to the precious metal and polymetal business, including:

- Precious metal purchases and sales.
- Refined bullion transactions.
- Concentrate, dore and other mineral products.
- International suppliers and buyers.
- Brokers, agents and intermediaries.
- Refineries and processing partners.
- Mining companies and mineral producers.
- High-value transactions.
- Cross-border payments and settlements.
- Third-party payments.
- Unusual transaction structures.




- Transactions involving higher-risk jurisdictions.

The Compliance Officer will work closely with Operations, Finance, Sales, Procurement and Senior Management to ensure that compliance requirements are incorporated into the transaction approval process.

5. Sanctions & Restricted-Party Screening

Implement and oversee screening procedures for:

- Customers.
- Suppliers.
- Beneficial owners.
- Directors and senior officers.
- Brokers and agents.
- Banks and financial counterparties.
- Shipping/logistics counterparties where appropriate.
- Other parties involved in material transactions.

Screening should address applicable Canadian sanctions and other relevant sanctions requirements based on the company's activities and jurisdictions.

Potential matches must be investigated, documented and escalated appropriately before transactions proceed.

6. PEP, HIO & High-Risk Relationships

Establish procedures for identifying:

- Politically Exposed Persons (PEPs).
- Heads of International Organizations (HIOs).
- Family members and close associates where applicable.
- High-risk individuals and entities.
- High-risk jurisdictions.
- Complex ownership structures.

Ensure enhanced measures are applied where required.

FINTRAC requires applicable reporting entities to make PEP/HIO determinations and apply additional requirements where those determinations are made.

7. Suspicious Transaction Monitoring & Reporting

- Develop and maintain transaction-monitoring procedures.
- Identify unusual or potentially suspicious transaction patterns.
- Investigate internal alerts and compliance referrals.
- Document investigations and decisions.
- Determine when escalation and regulatory reporting are required.
- Prepare and submit Suspicious Transaction Reports (STRs) to FINTRAC when required.
- Maintain confidentiality surrounding STR-related matters.
- Establish appropriate escalation procedures for potentially fraudulent, sanctioned or otherwise prohibited activity.

The Compliance Officer must ensure that employees understand their responsibility to identify and escalate potentially suspicious activity.

8. Risk Assessment

Develop and maintain an enterprise-level AML/ATF and sanctions risk assessment considering factors such as:

- Customer risk.
- Geographic risk.
- Product and service risk.
- Transaction risk.
- Delivery/channel risk.
- Supplier and counterparty risk.
- Ownership structures.
- International exposure.
- Precious-metals sourcing and trading activities.

FINTRAC requires reporting entities to assess and document money-laundering, terrorist-financing and sanctions-evasion risks and to apply enhanced measures where risks are identified as high.

9. Compliance Training

Develop and deliver ongoing compliance training for employees whose responsibilities expose them to compliance risks.

Training may include:

- FINTRAC requirements.
- AML/ATF fundamentals.
- KYC/KYB.
- Beneficial ownership.
- PEP/HIO requirements.
- Sanctions.
- Suspicious transaction indicators.
- Transaction escalation procedures.
- Record keeping.
- Fraud prevention.
- Precious-metals-specific AML risks.

Training should be appropriately tailored to different departments and job functions. FINTRAC requires an ongoing written compliance training program and documented training plan.

10. Internal Compliance Reviews & Audits

- Conduct periodic compliance testing.
- Review customer and transaction files.
- Test KYC/KYB procedures.
- Test sanctions-screening controls.
- Review regulatory reporting processes.
- Identify control deficiencies.
- Develop corrective action plans.
- Track remediation through completion.
- Coordinate independent compliance reviews where appropriate.

FINTRAC requires reporting entities to conduct an effectiveness review of their compliance program at least every two years.

11. Policies, Procedures & Governance

Develop and maintain policies covering, as applicable:

- AML/ATF.
- KYC/KYB.
- Customer risk classification.
- Beneficial ownership.
- PEP/HIO.
- Sanctions.
- Source of funds/source of wealth.
- Suspicious transaction escalation.
- Transaction approval.
- Third-party payments.
- High-risk jurisdictions.




- Record retention.
- Employee compliance.
- Conflict of interest.
- Fraud prevention.
- Whistleblower/escalation procedures.

Ensure policies are communicated to relevant employees and consistently implemented.

12. Senior Management Reporting

Provide regular reporting to senior management regarding:

- Compliance risks.
- High-risk customers and counterparties.
- Significant compliance investigations.
- STR activity and trends, as appropriate.
- Sanctions alerts.
- KYC deficiencies.
- Outstanding remediation items.
- Regulatory developments.
- Compliance training.
- Internal testing results.
- Recommended improvements.

The Compliance Officer must maintain sufficient independence to escalate material concerns directly to senior management.

Required Qualifications

Education

- Bachelor's degree in Finance, Accounting, Business, Law, Compliance, Risk Management or a related discipline preferred.
- Professional compliance, AML or financial-crime certification is an asset.

Experience

5+ years of relevant compliance, AML, financial crime, risk, audit or regulatory experience, preferably within one or more of the following:

- Precious metals.
- Mining.
- Commodity trading.
- Financial services.
- Banking.
- Securities.
- International trade.
- Money services.
- Refining.
- Jewellery/precious metals.
- Corporate investigations.

Experience working directly with FINTRAC and Canada's AML/ATF regulatory framework is strongly preferred.

Preferred Certifications

One or more of the following would be considered an asset:

- CAMS — Certified Anti-Money Laundering Specialist
- CFCS — Certified Financial Crime Specialist
- CFE — Certified Fraud Examiner
- Canadian compliance or risk-management designation
- Legal or accounting designation

Knowledge & Technical Skills

The successful candidate should demonstrate strong knowledge of:

- FINTRAC requirements.
- PCMLTFA and associated Regulations.
- AML/ATF compliance.
- KYC/KYB.
- Beneficial ownership.
- PEP/HIO requirements.
- Sanctions compliance.
- Transaction monitoring.
- Suspicious transaction investigations.
- Risk assessment.
- Enhanced due diligence.
- Source of funds/source of wealth.
- Compliance documentation.
- Regulatory reporting.
- Internal controls and audit processes.

Experience with compliance/KYC platforms, sanctions-screening systems, transaction-monitoring systems and corporate registry databases is an asset.

Key Competencies

- High integrity and professional judgment.
- Strong attention to detail.
- Excellent analytical and investigative skills.
- Ability to identify unusual transaction patterns.
- Strong written and verbal communication.
- Ability to challenge business decisions when compliance risks are identified.
- Strong documentation and organizational skills.
- Ability to work independently.
- Ability to handle highly confidential information.
- Strong understanding of international business and cross-border transactions.
- Ability to work effectively with executives, finance, operations, sales and external advisors.

Independence & Authority

The Compliance Officer / Manager will have appropriate independence and authority to:

- Request additional documentation from customers and counterparties.
- Escalate high-risk relationships.
- Require enhanced due diligence.
- Recommend transaction holds pending compliance review.
- Escalate potential sanctions or AML concerns to senior management.
- Recommend declining or terminating relationships where compliance requirements cannot be satisfied.
- Access records and information necessary to perform compliance responsibilities.

The position will have direct access to senior management regarding material compliance matters.

What We Offer

- Senior-level position within a growing Canadian precious metals and polymetal business.
- Chance to build and lead the company's compliance framework.
- Direct exposure to international commodity transactions.
- Competitive compensation based on experience.
- Performance-based bonus opportunity.
- Professional development and certification support.
- Opportunity for long-term advancement within the organization.

Application

Interested candidates should submit a resume and cover letter outlining their experience with FINTRAC, AML/ATF, KYC/KYB, sanctions compliance and high-value or international transactions.

Candidates with direct experience in precious metals, mining, commodities, refining or international trading are encouraged to apply.

Pay: $70,000.00-$100,000.00 per year

Work Location: In person

📌 Compliance Officer (Canada)
🏢 PMW
📍 Canada