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.

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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.

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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.

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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.

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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;

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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.

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FINTRAC’s 2016 Real Estate Brief

Rodney MacInnes on December 23, 2016

Quick Overview

A little over a month ago, FINTRAC published an operational brief for the Canadian real estate industry.  The brief was intended to assist reporting entities in meeting the obligations to report suspicious transactions or attempted suspicious transactions that related to potential money laundering or terrorist financing.  The publication provided some common indicators that may be present in a transaction that suggest money laundering or terrorist financing could be involved.

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Would You Recognize Real Estate Red Flags?

Rodney MacInnes on November 30, 2016

Rodney_FINTRACOn November 14th, 2016 FINTRAC released a brief for all reporting entities who may be involved in real estate transactions.  The briefing is intended as guidance to provide some examples of indicators that may be present in transactions that may suggest they are linked to money laundering or terrorist financing.  The indicators described have been taken from transactions suspected of being related to money laundering or terrorist financing reported internationally.  The briefing focuses on the potential risks and vulnerabilities within the real estate industry and provides suggestions on how to ensure reporting entities are sufficiently meeting suspicious transaction reporting obligations.

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Sanctions This Week: July 25th – 29th, 2016

Rodney MacInnes on August 3, 2016


OSFISanctions Pic

There were no updates released from OSFI this week.

Go to the OSFI lists page.


The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released four updates last week.  One update was related to the publication of Cuba-related Frequently Asked Questions (FAQ), covering some of the recent changes made to the sanctions that had previously been placed on Cuba.  Other updates included the removal of 12 individuals from the Counter Terrorism Designations List, the issuance of a Finding of Violation and the publication of Iran General License J.

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Sanctions This Week: July 18th – 22nd, 2016

Rodney MacInnes on July 25, 2016


On July 18th and 22nd, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC’s) Al’Qaida and Taliban regulations updates to the sanctions list, deleting one individual and amending another.

Read more on Sanctions This Week: July 18th – 22nd, 2016…