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Information Should Be Free!

Rodney MacInnes on April 26, 2019

Outlier has produced an open-source AML and CTF, and Privacy repositories of definitions, acronyms, and terminology that is free for whoever wants it.

Please feel free to provide contributions and/or feedback, as it would be greatly appreciated. We have already had three contributors!

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FINTRAC Alert – Laundering the Proceeds of a Romance Scam

Rodney MacInnes on April 15, 2019

Quick Overview

On April 11th, 2019, FINTRAC published an Operational Alert issued in part with the Canadian Anti-Fraud Centre.  The information provided related to laundering the proceeds of romance scams and mass marketing fraud. The publication provided an explanation of what constitutes a romance scam, some common indicators that may be present and transaction patterns or flow of funds that may suggest fraud.

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Technology and Cyber Security Incident Reporting

David Vijan on January 28, 2019

The issue of cyber security incidents seems to continue to be a hot topic for regulators. Late last year, federal Breach of Security Safeguards Regulations came into force, which require organizations to report to the Office of the Privacy Commissioner (OPC), any breach of security safeguards involving personal information under its control where the breach creates a “real risk of significant harm”. Last week, The Office of the Superintendent of Financial Institutions (OSFI) published an advisory, Technology and Cyber Security Incident Reporting, which sets out OSFI’s expectations for Federally Regulated Financial Institutions (FRFIs) with respect to the reporting of technology and cyber security incidents. The advisory  becomes effective on March 31, 2019.

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Meaningful Consent

David Vijan on January 15, 2019

Meaningful Consent

The Office of the Privacy Commissioner of Canada’s Guidelines for obtaining meaningful consent became effective on January 1, 2019. The new guideline builds on examining the current state of consent in Canada (see Background section below), and is meant to assist businesses in distinguishing between those things an organization “must do” to obtain meaningful consent, and those things an organization “should do” related to consent.

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Are On Demand Products Right For You?

Amber D. Scott, Founder & Chief AML Ninja on December 6, 2018

For certain industries, including dealers in precious metals and stones (DPMSs) and real estate, Outlier’s on-demand products are anti-money laundering (AML) and counter terrorist financing (CTF) programs that you can buy, customize online using our set up wizard, and download in fully customizable formats.

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Mandatory Breach Reporting under PIPEDA

David Vijan on November 8, 2018

Back in late 2017 we published an article on breach reportingOn November 1, 2018, the new provisions to the Personal Information Protection and Electronic Documents Act (PIPEDA) related to breach of security safeguards along with the Breach of Security Safeguards Regulations came into force.

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Now We Wait… Canada’s Proposed AML Updates

Amber D. Scott, Founder & Chief AML Ninja on September 9, 2018

As of last Friday (September 7, 2018) the comment period for Canada’s draft AML amendments has closed (if you have something to say, they’ll likely still accept submissions for a few more days).

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Real Estate Sector – Identifying Individuals

David Vijan on August 29, 2018

We often hear friends and clients in the real estate sector say they are frustrated that there are not many ways to identify a customer other than meeting them face-to-face. Real estate developers, brokers and sales representatives have an obligation to ascertain a customer’s identity which requires them to refer to specific information and/or documentation to verify a customer’s identity.  However, this does not mean that identification must take place face-to-face. Below is a summary of all the different methods outlined in FINTRAC Guidance that are currently available to identify customers that are individuals and what’s coming.[1]

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Outlier Is Hiring

Amber D. Scott, Founder & Chief AML Ninja on August 22, 2018

Outlier Solutions Inc. (Outlier) is hiring for the position of Admin Assistant, Office Co-ordinator & Jack and/or Jill of All Trades.

Start-Up Life

While Outlier has been operating successfully for five years, we are still in many ways a start-up. As we grow, we need to add a team member to get/keep us organized. We’re experts at documenting processes for our clients, but we haven’t always been great at documenting our own processes. This puts us at risk of missing things as we grow – which is an ironic problem for a risk management company, isn’t it? This will begin as a part-time position with the potential to grow into a full-time position. Hours and working location are flexible (meaning that if you need to pick up the kids, go to class, or just flat out need to take a day to get things done you’ll be able to schedule around it).

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Why rich people don’t just open a bank…

Amber D. Scott, Founder & Chief AML Ninja on August 2, 2018


It can be tough to open and maintain a bank account as a crypto-business. A policy of “derisking” (when banks avoid conducting business with customers perceived as being higher risk) leaves many crypto-businesses (and other MSBs) ill-served by the existing banking system.

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