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As a company that gets to work with a lot of startups, and existing companies entering the Canadian market, we get to help folks understand the regulatory landscape in Canada. One of the required elements of a Canadian compliance program is an AML Compliance Effectiveness Review. These reviews must be completed every two years at a minimum. You can think of it like an audit, but for compliance.
Read more on First AML Compliance Effectiveness Review Timing…
If you had told me ten years ago that I would be in the longest-running position in the history of my career, I wouldn’t have believed you. Back then, I was unhappy for various reasons, and while I had started to think about what I really wanted from my work life, I had yet to take some of the big steps to get there. I won’t go into the gory details of where I was or the situations that weren’t working for me. Suffice it to say that there was a lot that wasn’t working, and I didn’t know how to fix it… but I had some ideas.
FINTRAC Registration
Over the past few months, we have heard from several money services businesses (MSBs) that have experienced issues in renewing their MSB registrations with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). In most cases, these issues are easily resolved. However, if MSB registration issues are not addressed promptly, administrative monetary penalties (AMPs) or criminal charges may ensue.
The Outlier Compliance Group team is thrilled to welcome our newest member, Karene Lewis!
Karene brings deep banking (including credit union) and money services business (MSB) experience.
Karene joins the Outlier team with more than 15 years of experience in the financial services sector; over 10 years of experience working in the Credit Union sector; over eight years of working experience building relationships with MSBs and PSPs, and enhancing and managing compliance programs for a variety of regulated entities.
Read more on Outlier Compliance Group welcomes Karene Lewis!…
On April 27th, 2022 amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) and associated regulations related to penalties for non-compliance were passed. These amendments were unusual, as there was little prior public consultation, no pre-publication for public comment, and they came into force “on publication” (right away). This is particularly unusual, as new business models were included in the money services business (MSB) and foreign money services business (FMSB) categories.
Read more on EFTs, PSPs & Crowdfunding : Canada’s Changing Regulatory Landscape…
Effective June 1, 2020, dealers in Virtual Currency activities were considered as Money Services Businesses (MSBs) and as such, must comply with MSB obligations under amendments made to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). One obligation is to have an AML effectiveness review at least once every two years. MSBs must start their effectiveness review no later than two years from the start of their previous review or in the case of dealers in Virtual Currency, no later than June 1, 2022, the date they were considered to be MSBs under law.
Read more on Effectiveness Reviews for Dealers in Virtual Currency…
BackgroundOn April 27, 2022 amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations were published in the Canada Gazette. To make reading these changes a little easier, we (thanks Rodney) have created a redlined version of the regulations, with new content showing as tracked changes, which can be found here.
We’re looking for an AML compliance person. Initially, this is going to be a part-time / backfill role, but we’d love for it to be a permanent role (either part time or full time, depending on the need and fit). We have a team member that will be taking some time off shortly, and we were at the point that we were talking about bringing on another compliance ninja before that. We take bringing on new team members very seriously. We’re a small group, and we work very well together. We’d be lying if we said that “can we just handle the work ourselves?” isn’t something that was brought up (multiple times). You’re reading this posting because we need a very capable human, and maybe that’s you.
We’ve missed you and we’re looking forward to welcoming you back in person!
As mask mandates lift in Canada and we have face-to-face meetings again, it’s important that we treat one another with dignity and respect. At Outlier, we’re experts in compliance risk management, but we are not medical experts. We respect your right to set your risk tolerance and believe that we should all have the freedom to do so without the need for detailed explanations. Our masking policy reflects this philosophy.
