Adding Value

Amber D. Scott, Founder & Chief AML Ninja on January 17, 2018

An Open Letter to the Blockchain Association of Canada & The Canadian Blockchain Community

My obsession (let’s call it what it is) with Bitcoin and blockchain was born in 2013 when I updated a risk assessment to include bitcoin (and accepted my first bitcoin payment). Soon after, I spoke at the Bitcoin Expo in Toronto and became a member of the Bitcoin Alliance of Canada (BAC). At the time, it seemed to me that so many wonderful things were happening in Canada. This organization had a real opportunity to transcend political leanings and model new methodologies for consensus and transparency. For what it’s worth, I still believe that this is possible if we have the will and dedication to do the work.

Read more on Adding Value…

FCAC Supervision Framework

David Vijan on November 15, 2017

The Financial Consumer Agency of Canada (FCAC) Supervision Framework updates and replaces FCAC’s current Compliance Framework. The updates provide a clearer and deeper understanding of how FCAC fulfills its mandate to protect financial consumer.

Read more on FCAC Supervision Framework…

The Secret Project: 2017

Amber D. Scott, Founder & Chief AML Ninja on October 18, 2017

Thank you to the Canadian MSB Association for allowing us to present our research findings at the 2017 Fall Conference.

Money Services Business (MSBO and bitcoin business banking in Canada is the most significant barrier to entry. We set out to prove that the derisking crisis is real. In a first world country, this is absurd.We hope that this research facilitates an open and honest dialogue, that includes those with the power to improve the situation.

Read more on The Secret Project: 2017…

Breach of Security Safeguards Regulations

David Vijan on September 15, 2017

Back in June of 2015, the Digital Privacy Act, received royal assent resulting in amendments to the Personal Information Protection and Electronic Documents Act (PIPEDA). Most amendments came into force at that time, except for the much-anticipated requirements related to breach notification. These requirements will come into force once regulations have been developed and put into place and will affect any organization that collects, uses or discloses personal information in the course of commercial activities.

Read more on Breach of Security Safeguards Regulations…

AML & Digital Currency in Canada

Amber D. Scott, Founder & Chief AML Ninja on July 25, 2017

Because we’ve been asked a time or two what’s new in AML & digital currency in Canada…

The following are a compilation of FINTRAC’s policy positions in relation to digital currency. This document is current as of July 25, 2017.

Read more on AML & Digital Currency in Canada…

Alert – Terrorist Property Reporting

David Vijan on July 17, 2017

FINTRAC has recently published their reorganized guidelines and one notable change to Guideline 1, in partial, is the change to the CSIS Financing Unit, unclassified fax.

  •  Old: 613-231-0266
  • New: 613-369-2303

Polices related to Terrorist Property Reports (TPRs) should be updated to reflect this change.

Read more on Alert – Terrorist Property Reporting…

Canada’s 2017 Budget & PCMLTFA Updates

Amber D. Scott, Founder & Chief AML Ninja on April 23, 2017

Greetings fellow compliance geeks!

As you may know, Canada’s latest budget bill contains a number of amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). We’ve created a marked up version of the PCMLTFA to help you work through and understand the changes, and you can access it using the link below with this caveat: you are welcome to use and share this markup, but you may not charge money for access to it. Information should be free.

Read more on Canada’s 2017 Budget & PCMLTFA Updates…

Security Alert: Password Reset Required

Amber D. Scott, Founder & Chief AML Ninja on February 25, 2017

This is a security alert for anyone that has set up an account on our website.

It is our responsibility to inform our clients about a potential data breach that may or may not have occurred over the past five months of CloudFlare, one of Outlier’s partners in managing the website.

Read more on Security Alert: Password Reset Required…

An MSB by Any Other Name

Amber D. Scott, Founder & Chief AML Ninja on January 16, 2017

What’s in an MSB?

Under Canadian federal legislation, a money services business (MSB), in Canada, is a person or entity engaged in the business of any of the following activities:

  • Foreign exchange dealing;

Read more on An MSB by Any Other Name…

AMF Examining Non-Quebec MSBs

Amber D. Scott, Founder & Chief AML Ninja on January 3, 2017

It has been a requirement for some time that money services businesses (MSBs) operating in Quebec become licensed with the Authorité des Marchés Financiers (AMF). We have recently learned that the AMF has begun to examine MSBs that are licensed, but do not have a physical presence in Quebec. Our colleague Michael Garellek of Gowling WLG (Canada) LLP has issued a useful practice note (below) with useful tips.

Read more on AMF Examining Non-Quebec MSBs…