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Dealers in Precious Metals & Stones

These documents walk you through what you need to do, step by step. You can purchase the program components separately or as a full package all at once.

AML & CTF Policy and Procedures

AML & CTF Risk Assessment

Compliance Effectiveness Review

Resources & Training

Background

Dealers in Precious Metals and Stones (DPMS) that operate in Canada are subject to Canadian anti money laundering (AML) and counter terrorist financing  (CTF) requirements.  The Canadian regulator is the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).  In addition to regulating the industry, FINTRAC receives reports from DPMS and publishes educational material for the industry.

How Outlier Can Help

Outlier has designed plain language AML and CTF compliance program components to help you meet your obligations.  These documents walk you through what you need to do step by step.  You can purchase program components either separately or as a package.  You will need customize the documents by adding information about your business, and keep them up to date.

If you are comfortable editing the documents on your own, you can preview and buy everything that you need here.  If you would like the assistance of a consultant, we can assist you as well.  All of our consulting engagements are fixed-fee, so you will know exactly what the cost is before we start working.

If you have been contacted by FINTRAC and require immediate assistance, please take a look at our FINTRAC resources page or contact us.

CJA & JVC Members

Members of the Canadian Jewellers Association (CJA) and Jewellers Vigilance Canada (JVC) can access content free of charge by logging into the CJA or JVC websites.

Program Components

AML & CTF Policy and Procedures

 

This document includes:

  • Roles & Responsibilities
  • FINTRAC Reporting
  • Internal Forms for Staff
  • Compliance Office Cheat Sheet

This document describes what you need to do in order to meet your AML and CTF obligations.

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The AML & CTF Policy and Procedures can be downloaded as a Word document that you can edit at any time, with comments to help you work through it. If you’re ready to get started and would rather answer questions about your business online, you can also choose to use our customization app. If you are using the customization app, you can save and come back to your work anytime in the next five years. The documents that you create can be downloaded in Word at the end of the questionnaire.

The AML & CTF Policy and Procedures are designed to work with a Risk Assessment. If you already have a Risk Assessment that you’re happy with, then this document can be used alone. It can also be bundled with our Risk Assessment or with our Compliance Effectiveness Review for a discount, or bundle all three for the best price.

AML & CTF Risk Assessment

 

This document includes:

  • Some items
  • that are not listed
  • in the Word document
  • provided by Amber.

This document is used to describe and rate the risk that your business could be used to launder money or finance terrorism.

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The Risk Assessment is used to explain your business model, provide a narrative about your risk, rate your risk, and describe the controls that you have in place to guard against that risk.

The Risk Assessment can be downloaded as a Word document that you can edit at any time, with comments to help you work through it. If you’re ready to get started and would rather answer questions about your business online, you can also choose to use our customization app. If you are using the customization app, you can save and come back to your work anytime in the next five years. The documents that you create can be downloaded in Word at the end of the questionnaire.

Compliance Effectiveness Review

 

This document includes:

  • Some items
  • that are not listed
  • in the Word document
  • provided by Amber.

A compliance effectiveness review is similar to an audit.

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A Compliance Effectiveness Review is required at least every two years and tests your compliance program and your operations (what you’re actually doing) against Canadian AML and CTF requirements. The Compliance Effectiveness Review has three fully editable components:

  • Reviewer Guide: this Word document helps the reviewer understand Canadian AML and CTF requirements for reviews.
  • Report: this Word document is used to create a final report that summarizes the testing that was completed and the test results.
  • Workbook: this Excel document provides a step-by-step list of the tests that will be conducted, and a place to record the results as the reviewer completes the testing.

Resources and Training

 

This document includes:

  • Some items
  • that are not listed
  • in the Word document
  • provided by Amber.

Your AML and CTF compliance training needs to cover at least the points listed here.

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Your staff should be trained when they begin working for you and every year after that. Training should cover:

  • What is money laundering?
  • What is terrorist financing?
  • Who is FINTRAC?
  • What is a DPMS?
  • What are our responsibilities under Canadian law?
    • Compliance Officer
    • AML Program
    • Risk Assessment
    • AML Compliance Effectiveness Review
    • Training
    • Reporting
    • Recordkeeping
    • Identifying Customers
    • Customer Risk
    • Transaction Monitoring
  • Who is our Compliance Officer?
  • What do I do if I believe that money laundering or terrorist financing is taking place?
  • What indicators should I look for in our transactions and customer behaviours?

Outlier can create customized training programs for you. If you are a mid to large sized operation, this can be a great choice. If you are a small business owner and looking for the most cost effective way to manage your training, there are some excellent free resources available. These can be combined with a session that you run for your staff that covers the specifics for your business.

Whether you choose to conduct training on your own, or with a little help, here are some great resources to get you started:

  • The Egmont Group’s AML & CTF Awareness video: an extremely well produced video that covers money laundering and terrorist financing basics. It is available in French, English and Spanish.
  • FINTRAC’s informational video “Your Role in Fighting Money Laundering and Terrorist Financing”: covers money laundering and terrorist financing basics and FINTRAC’s mission.
  • FINTRAC’s informational video “The Case”: follows a money laundering investigation.
  • FINTRAC’s 2008 Webinars on Obligations For DPMSs: a series of three videos that explain the obligations that apply to DPMSs. While these videos are still useful, some elements of the regulations have changed since 2008.

Remember to keep a record of the training that was completed. Your records should include what topics were covered, who was trained and when.

Canadian Jeweller’s Association

Members of the Canadian Jewellers Association (CJA) can use the same log-in used for CJA’s website to access free resources, including:

  • AML & CTF Policy and Procedures
  • AML & CTF Risk Assessment
  • Compliance Effectiveness Review

CJA members also receive a discount on additional consulting services purchased through Outlier.