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.



Recently the Compliance Officer from a small 

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. 