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Fraud & Reasonable Grounds to Suspect

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on January 10, 2022

One of the themes that was prevalent in Canadian AML for 2021 was the relatively low bar represented by “reasonable grounds to suspect” (RGS) and the types of transactions for which FINTRAC expected suspicious transaction reports (STRs) to be filed. One of our astute colleagues worked with us to craft some specific scenarios (the full version, including FINTRAC’s response, can be viewed here), and FINTRAC’s response seems to confirm a significant shift in position from previous discussions. Specifically, STRs are expected in cases of fraud, including cases in which the reporting entity’s client is believed to be the victim of fraud.

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Proliferation Financing

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on January 4, 2022

 

 

 

 

What is it, and why should AML compliance professionals be paying attention?

If you’ve looked at the Financial Action Task Force (FATF)’s recommendations recently, you’ve no doubt noticed that there are now three big topics on the covering page:

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888 – Reflecting 8 Great Years!

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on December 31, 2021

On August 8th (the 8th day of the 8th month) this year, Outlier Compliance Group turned 8 years old. It seems like a good time to stop and reflect on the company’s journey to this point, and where we’re going next…

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Don’t Share STRs or STR Data

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on February 3, 2021

Recently the Compliance Officer from a small reporting entity reached out to me to ask an uncomfortable question: should they provide copies of the Suspicious Transaction Reports (STRs) that they had filed with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) to their financial services providers such as a credit union or bank?

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FINTRAC Examinations for the Real Estate Sector

David Vijan, Co-Founder & CEO on January 5, 2021

We often hear friends and clients in the real estate sector say they are unsure what to expect if (and when) the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) notifies them of an examination. This article is meant to provide guidance on what to expect and how to ensure a smooth review.

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Changes to PIPEDA, Canada’s Private-Sector Privacy Law

David Vijan, Co-Founder & CEO on November 23, 2020

Background

On November 17, 2020, Bill C-11, the Digital Charter Implementation Act, 2020 was introduced. If passed, the proposed Act would repeal part 1 of the Personal Information Protection and Electronic Documents Act (PIPEDA) and a new Consumer Privacy Protection Act (CPPA) would regulate the way in which personal information is collected, used and disclosed by private sector organizations in the course of their commercial activity.

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In Memoriam: Colleen P. Waddell

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on September 25, 2020

It is with great sadness that we inform you of the passing of Colleen P. Waddell. Colleen passed away on September 23, 2020. She was both a valued member of the Outlier team, and a friend to many Outlier ninjas and clients. She will be missed. 

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The Iran Ministerial Directive’s Impact

Rodney MacInnes, CRO & AML Compliance Ninja on July 29, 2020

Quick Overview

On July 25, 2020, a new Ministerial Directive (MD) was published in the Canada Gazette by the Minister of Finance on financial transactions associated with the Islamic Republic of Iran.  On July 27, 2020, FINTRAC issued guidance on how to incorporate the MD into your anti-money laundering (AML) program, along with some indicators for determining if a transaction is associated with Iran. This MD requires that every transaction originating from or bound for Iran be treated as high risk, regardless of the amount. This includes identifying every client, performing customer due diligence, and recording certain information. It is vital that your AML compliance program documentation contains internal processes related to MDs, even if you do not conduct transactions with Iran (or North Korea, based on the previous MD issued December 9, 2017).

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Amended AML Regulations June 10, 2020 – Redlined Versions

Rodney MacInnes, CRO & AML Compliance Ninja on June 10, 2020

The following red-lined versions have been created to reflect final amendments to Canadian anti-money laundering (AML) laws & regulations published in the Canada Gazette on June 10, 2020.  Amendments to the Cross-border Currency and Monetary Instruments Reporting Regulations will come into force on June 1, 2020. All other amendments will come into force on June 1, 2021. We have created industry specific blogs to make understanding the changes easier, which are located here.

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Amending the Amendments! 2020 AML Changes for Real Estate

David Vijan, Co-Founder & CEO on June 10, 2020

Background

Back on July 10, 2019, the highly anticipated final version of the amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its enacted regulations were published. However, on June 10, 2020, further amendments to those amended regulations were published in the Canada Gazette. To make reading these changes a little easier, we have created a redlined version of the regulations, with new content showing as tracked changes, which can be found here.

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