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Amendments To The Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations – 2022

Background

On 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.

The Regulatory Impact Statement for these changes state the following:

Crowdfunding platforms and some payment service providers are not currently covered by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and therefore have no money laundering and terrorist financing obligations under federal statute. This lack of oversight presents a serious and immediate risk to the security of Canadians and to the Canadian economy. This risk was highlighted in early 2022, when illegal blockades took place across Canada that were financed, in part, through crowdfunding platforms and payment service providers. Allowing these gaps to continue represents a risk to the integrity and stability of the financial sector and the broader economy, as well as a reputational risk for Canada.

Amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, and consequential amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations, will help prevent the financing of illegal activities through these types of financial services.

What’s Changed?

The changes are substantial and sudden. They will affect many companies that have not been previously under the purview of AML regulation in Canada. These changes are effective immediately and there is no comment period, which is not the norm for such changes.

To help digest these changes, we have summarized what we feel are the most important changes below:

The definition for an electronic funds transfer has been removed and the corresponding section within the body of the regulations was amended. Previous exemptions related to remitting or transmitting from one person or entity to another by Credit or Debit Card, or Prepaid Payment Product if the beneficiary has an agreement with the payment service provider that permits payment for the provision of goods and services, has been revoked for money services businesses, which as we mentioned now includes Payment Service Providers.

The definitions section was amended by adding the following:

  • crowdfunding platform means a website or an application or other software that is used to raise funds or virtual currency through donations. (plateforme de sociofinancement)
  • crowdfunding platform services means the provision and maintenance of a crowdfunding platform for use by other persons or entities to raise funds or virtual currency for themselves or for persons or entities specified by them.

With these changes, crowdfunding platforms and payment service providers will now be subject to existing money services businesses requirements. These obligations include:

  • Registration with FINTRAC;
  • Developing a compliance program;
  • Customer identification and due diligence;
  • Transaction monitoring and customer risk scoring;
  • Reporting certain transactions to regulators and government agencies;
  • Complying with Ministerial Directives; and
  • Keeping records.

Specific to record keeping, crowdfunding platforms that provide services to persons or entities in Canada where a person donates an amount of CAD 1,000 or more in funds or virtual currency will need to:

(a) keep an information record in respect of the person or entity to which they provide those services;

(b) keep a record of the purpose for which the funds or virtual currency are being raised; and

(c) if the person or entity for which the funds or virtual currency are being raised is different from the person or entity referred to in paragraph (a),

      1. keep a record of their name, and
      2. take reasonable measures to obtain their address, the nature of their principal business or their occupation and, in the case of a person, their date of birth, and keep a record of the information obtained.

What Next?

Due to these changes, FINTRAC will need to revise its interpretation of existing requirements to include crowdfunding platforms and payment service providers. There is no set date for when we can expect guidance from FINTRAC. Additionally, various FINTRAC policy interpretations will no longer be able to be relied upon (i.e. policy interpretations related to merchant services as well as payment processing for utility bills, mortgage and rent, payroll, and tuition being exempt from AML obligations). The hope is FINTRAC will issue new policy interpretations, but for now the industry is left with many questions.

We’re Here To Help

If you would like assistance in understanding what these changes mean to your business, or if you need help in creating or updating your compliance program and processes, please get in touch.

We’re Hiring!

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.

While we know many great folks, we’ve chosen to post this role publicly in the interest of widening the possible field to include candidates that we might not know personally.

What does the job actually entail?
We’re compliance consultants. Our practice includes anti-money laundering (AML), privacy, and regulatory compliance. Most of the companies that we work with are AML reporting entities (banks, credit unions, money services businesses, securities dealers, dealers in precious metals and stones, etc.). Our work is project based. Those projects include:

  • Developing and updating policies, procedures and risk assessments;
  • Designing and delivering training;
  • Conducting effectiveness reviews;
  • Helping clients to prepare for reviews and regulatory examinations;
  • Helping clients to remediate review and regulatory examination findings; and
  • Helping clients with compliance related questions.

In order to do this effectively, we believe that you need to have deep, hands-on experience in these areas. This is why all of our team members have over 10,000 hours of in-house compliance experience. This is non-negotiable.

What you’ll love about working at Outlier
We think that our team is pretty great: we’re all professional, friendly, and incredibly nerdy.

No two days are the same: we work on different projects that move at different paces. As long as the desired outcome is delivered on time, you can work at your pace from your location. Occasionally we may need to be onsite with our clients but most work is done remotely.

Our clients are professionals, entrepreneurs and thought leaders: we learn as much from our clients as they learn from us. It is often an absolutely incredible journey.

The compensation model is radically transparent and tied to individual performance: our consultants earn a share of the revenue related to each project in which they participate. These are democratic decisions that are visible to the whole team, ensuring fairness.

What might terrify you, but shouldn’t stop you
We think that our team is pretty great: at first, we’re going to seem intimidating and cliquey. We’ll do everything that we can to bring you into the fold, but you’re going to have to identify and ask for what you need.

No two days are the same: sometimes things get hectic and it can be stressful. You’ll need to be able to provide your own structure and manage your own schedule.

Our clients are professionals, entrepreneurs and thought leaders: they will push boundaries and ways of thinking, and they won’t always be compliance-minded.

The compensation model is radically transparent and tied to individual performance: openly discussing compensation can be awkward at first. We’ll try to remember that and be empathetic.

Some things that we think are probably true about the right candidate

  • You’re really good at what you do, but you are never satisfied.
  • Every time you’ve left a job, they’ve had to hire several people to replace you. You try not to gloat about this too much, but sometimes you can’t help it.
  • When put in charge of a well-functioning system, you’re likely to test “process improvements” until something breaks.
  • You’re at your very best when you’re fixing something broken or building something new – those challenges invigorate you.
  • When a business person tells you what they want to build, you immediately start thinking about how to execute their ideas within the parameters of existing law and regulation.
  • The phrase “that’s the way we’ve always done it” makes you either shudder or clench your jaw.
  • In your spare time, you probably also make or build something.

Want to apply?
Send an email with your resume attached in PDF format to: ninjas@outliercanada.com by May 13, 2022.
The subject line should read: Compliance Ninja, 2022
In the body of the email, please indicate why you believe that you would be a good fit, referencing this posting, as well as where you clocked your 10,000 hours of in-house compliance practice. Please feel free to include any questions that you have for us at the outset as well.
Please note that messages submitted in any other formats via any other channels will not be considered. Only applicants selected for an interview will be contacted.

Outlier Solutions Inc. Offering Compliance Services to the Metaverse in Decentraland

February 23, 2022 Toronto — Outlier Solutions Inc. doing business as Outlier Compliance Group, a consultancy specializing in compliance solutions for reporting entities ranging from banks to dealers in virtual currencies (like bitcoin) to real estate firms, is one of the first to offer compliance services in the metaverse. Outlier will be joining as one of the professional service providers setting up shop in conjunction with Grinhaus Law Firm, a leading Canadian law firm in Blockchain regulatory advisory, and DGM Financial Group, a prominent Trust and corporate services office which helps structure crypto businesses internationally, in Decentraland, to service clients globally and through the metaverse.

Visitors to Decentraland will now be able to visit Outlier’s office, and book meetings with one of the team members. Visitors can discuss their Canadian compliance needs on topics such as Canadian anti-money laundering (AML), anti-terrorist financing (ATF), privacy, and regulatory compliance management. Virtual spaces include traditional offices and a fountain (and of course, meetings can also be requested in person and via more traditional virtual meeting software). The Decentraland office is located at -39, 121, in the same neighbourhood as Decentraland University.

“The world, actual and virtual, is evolving rapidly” said Outlier’s Co-Founder and CEO, Amber D. Scott. “It’s important to understand what shape that evolution is taking, and no better way to learn than to be involved directly.” She adds, “It just makes sense that in order to be good advisors to companies operating in the metaverse, we would be there too.”

Scott’s avatar in Decentraland checks out the new virtual office space.

Founder of Grinhaus Law Firm, Aaron Grinhaus, stated, “we are pleased to welcome Outlier Solutions Inc. and complement our line up of professional services to help people and businesses navigate the ‘gray areas’ and legitimize the existence of the metaverse.”

Decentraland, with its 800,000+ residents and $54B in transactions, is also home to a wide array of companies and institutions from academia to crypto companies to fashion. This represents an opportunity to strategically grow Outlier’s presence as well as participate in the booming growth and creation in the metaverse.

Please direct media inquiries to decentraland@outliercanada.com.

About Outlier Solutions Inc.
Outlier Solutions Inc. dba Outlier Compliance Group is a Canadian consulting firm, founded in August of 2013, which is focused on developing compliance solutions for reporting entities. Outlier’s areas of expertise include anti-money laundering (AML), anti-terrorist financing (ATF), privacy, and regulatory compliance.

For further information please visit https://www.outliercanada.com

About Grinhaus Law Firm
Grinhaus Law Firm was established in 2012 and is a business, tax and regulatory focused firm with a niche expertise in Blockchain and Smart Contract law.

For further information please visit https://grinhauslaw.ca

About DGM Financial Group
DGM Financial Group is a global financial services firm that provides Trust Administration, Corporate Services, Management Services to insurance and non-insurance companies, Family Office, Director Services, and is a Listing Sponsor on the Barbados Stock Exchange.

For further information please visit https://dgmfinancialgroup.com/

About Decentraland
Decentraland is the first fully decentralized virtual world. Powered by DAO, which owns the most important smart contracts and assets of Decentraland. Decentraland is a software running on Ethereum that seeks to incentivize a global network of users to operate a shared virtual world. Decentraland users can buy and sell digital real estate, while exploring, interacting and playing games within this virtual world.

For further information please visit https://decentraland.org

Fraud & Reasonable Grounds to Suspect

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.

Here is a scenario that we asked about:

Scenario 2

A client reaches out to notify us that they sent the virtual currency to another party who promised them a generous short-term return. The client never received the promised funds and believes they have been defrauded. We review the customer account activity and do not find any anomalous activity either prior to or after the client sent the virtual currency to the wallet provided by the fraudster. The client appears to have sent their own funds to the fraudster and there is no account activity corresponding to any irregular transactions, including money mule indicators. Our client is simply a victim of fraud.

Based on strictly these facts, context and indicators, we have not reached reasonable grounds to suspect any money laundering or terrorist financing offences by our client. There may be downstream suspicion related to the wallet where the fraudulently obtained funds were sent but we do not have any suspicion based solely on our client’s transactions which include the transmission of virtual currency to that other wallet. We do not have any information or suspicion related to the other wallet except for the knowledge that our client’s virtual currency was sent to it.

Given the above, we believe no STR would be required. Could you please confirm our position? If the position taken here does not seem correct, please provide an underlying rationale.

And an excerpt from FINTRAC’s response:

In scenario 2, an STR should be submitted if the reporting entity reached reasonable grounds to suspect that the transaction or attempted transaction is related to fraud.

Not Just for Virtual Currency

While the scenario that we’ve provided is specific to virtual currency, the implications of this policy interpretation are not limited to transactions that involve virtual currencies. Every reporting entity type will deal with suspected and confirmed cases of fraud that touch their business models.

Why Does It Matter

To really get to why this matters so much, we need to first look at the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), which is where the requirement is first defined in Section 7:

Transactions if reasonable grounds to suspect

7 Subject to section 10.1, every person or entity referred to in section 5 shall, in accordance with the regulations, report to the Centre every financial transaction that occurs or that is attempted in the course of their activities and in respect of which there are reasonable grounds to suspect that

(a) the transaction is related to the commission or the attempted commission of a money laundering offence; or

(b) the transaction is related to the commission or the attempted commission of a terrorist activity financing offence.

This is important as the provision of the PCMLTFA (the section number) is what’s listed in the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations, where potential penalties are defined. Violations of Section 7 of the PCMLTFA are considered “very serious”. In turn, a “very serious” violation can lead to a penalty of up to $500,000 – for each instance.

If you’re a quantitative type quietly working out the rough number of fraud cases that your reporting entity has had recently, multiplying by $500,000, and feeling a bit nervous, you are not alone.

What’s Next?

While guidance and policy interpretations do not carry the force of law, this is often a distinction without a difference. Might a reporting entity take an appeal to federal court and win? Perhaps…though under the existing rules, that reporting entity’s name will be published (required where the violation is considered to be “very serious”), which for some reporting entities would have significant consequences, including the loss of vital banking partner relationships. Further, the cost of competent representation in a federal appeal process is well beyond the means of most small and mid-sized reporting entities.

Industry associations will, no doubt, continue to lead important conversations with FINTRAC and seek clarification for their members.

In the meantime, for most Canadian reporting entities, the most pragmatic decision will likely be to devise internal guidelines that include reporting STRs related to fraud cases.

Need a Hand?

If you want to make updates to your compliance program to reflect this new policy interpretation, or assistance with Canadian AML generally, please contact us.

Proliferation Financing

 

 

 

 

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:

  • Money laundering,
  • Terrorist financing, and
  • Proliferation.

The last of these has received considerably less attention until recently, and in many cases, it may not be explicitly included in either jurisdiction-specific legislation or compliance programs. While some elements of proliferation are generally included (for instance, it is rare to see a compliance program that does not address sanctions-related list screening), there is often little if any consideration given to risks such as sanctions evasion or the non-implementation of sanctions.

According to the FATF, weapons of mass destruction (WMD) proliferation refers to the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both dual-use technologies and dual use goods used for non-legitimate purposes). The financing of proliferation refers to the risk of raising, moving, or making available funds, other assets or other economic resources, or financing, in whole or in part, to persons or entities for purposes of WMD proliferation, including the proliferation of their means of delivery or related materials (including both dual-use technologies and dual-use goods for non-legitimate purposes). There are targeted financial sanctions intended to prevent specific jurisdictions, organizations, and persons from participating in any proliferation-related activities.

In Canada, reporting entities have strict obligations to comply with sanctions requirements.

Similarly, terrorists and terrorist groups are often subject to financial sanctions and prohibitions. All accounts and transactions are scanned against listed persons and entities. In the case that we have property (including money and investments) in our possession that belongs to a listed person or entity, it must be frozen and reported immediately.

Recommendation 1 requires countries and private sector entities to identify, assess, and understand “proliferation financing risks”. In the context of Recommendation 1, “proliferation financing risk” refers strictly and only to the potential breach, non-implementation or evasion of the targeted financial obligations referred to in Recommendation 7. These R.7 obligations apply to two country-specific regimes for the Democratic People’s Republic of Korea (DPRK) and Iran, require countries to freeze without delay the funds or other assets of, and to ensure that no funds and other assets are made available, directly or indirectly to or for the benefit of (a) any person or entity designated by the United Nations (UN), (b) persons and entities acting on their behalf or at their direction, (c) those owned or controlled by them. The full text of Recommendations 1 and 7 is set out at Annex A.

Canadian reporting entities will be familiar with Ministerial Directives related to North Korea and Iran that impose additional requirements, as well as providing indicators of activity related to these jurisdictions. While we may not be used to thinking about these requirements as being controls related to proliferation financing risk, this is exactly what they are. We may also fail to consider how they fit into our overall compliance regimes.

Proliferation Financing Trends and Typologies

It is not enough to simply say that your business does not deal with these jurisdictions directly. In many cases, funds are not actually repatriated to these jurisdictions but are held in other countries. For instance, identified state-sponsored North Korean hacking groups have moved stolen funds and virtual currencies through the Philippines, Macau, and China. In addition, actors intending to circumvent sanctions are known to be relatively proficient in using false and manufactured identities, as well as well as organizational structures intended to obfuscate true beneficial ownership. In the FATF’s webinar on proliferation financing, the global watchdog noted that proliferation financing may be one of the most challenging threats to detect in action, due to its complex nature.

Helpful Resources

Late in 2021, the FATF conducted an excellent webinar on proliferation financing risk assessment and mitigation, which has now been posted publicly. This presentation includes an excellent high-level overview, as well as detailed discussions of the trends and typologies that are relevant today.

It can be useful to review the aspects of the FATF’s recommendations that refer to proliferation.

There is additional guidance from the FATF on proliferation financing risk assessment and mitigation. This is a detailed document focused entirely on proliferation financing, and the FATF’s expectations.

The UK has conducted a national level assessment of proliferation financing risk. This includes a number of relevant case studies and typologies. If you want the sense of it, but are short on time, our friend Dev Odedra has published a summary.

Manchester CF has launched a proliferation financing training module as part of the Financial Intelligence Specialist (FIS) designation, offered in conjunction with the University of Newhaven.

Need a Hand?

If you want to get ahead of the curve by having a conversation about proliferation financing risk and potential impacts to your compliance program, please contact us.

Don’t Share STRs or STR Data

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?

This was a difficult situation for the reporting entity’s Compliance Officer because they were afraid of pushing back too much with the financial services provider. Like most non-bank reporting entities, they rely heavily on the services provided by the bank in order to be able to operate their business. Financial service providers, such as banks and credit unions, have the ability to close the accounts of businesses in Canada (often called de-risking), and it can be difficult for some types of reporting entities to establish new banking or payments relationships. The financial services provider in this situation has significantly more power than the reporting entity that is dependent on them.

My gut reaction was that the reporting entity should not disclose the contents of their STR reports, or provide copies. In Canadian legislation, disclosing the fact that an STR was made, or disclosing the contents of such a report, with the intent to “prejudice a criminal investigation” can be punishable as a criminal offence, with penalties of up to 2 years imprisonment (this is also known as “tipping off”). While there did not appear to be any intent to prejudice a criminal investigation in this case, it still seemed like a bad idea. I did a quick check-in with fellow AML geeks on LinkedIn. There are some great comments here, and I had a number of conversations in DMs and by phone. No one seemed to think that the reporting entity should be providing copies of STRs.

The question then became how to best empower the reporting entity to push back effectively. I submitted the following request to FINTRAC and to the Office of the Privacy Commissioner (OPC), both of which have mechanisms to allow Canadians and Canadian companies to ask the regulators to opine on matters free of charge:

One of our clients, a Canadian Money services business (MSB) has been asked by their financial services provider (bank/credit union) to provide copies of the suspicious transaction reports (STRs) and Attempted Suspicious Transaction Reports (ASTRs) that have been filed with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) on an ongoing basis. This struck us as being an overreach in terms of the information that should be disclosed to a service provider, and we are reaching out for an opinion on the appropriateness of these requests.

The financial service provider appears to be of the opinion that this is a reasonable request, and that they may close the MSB’s bank account if the STRs and ASTRs are not provided by the MSB.

I let both FINTRAC and OPC know that I had submitted requests to both. So far, only FINTRAC has responded. Their response is below in full (TL:DR: reporting entities should not share copies of STRs reported to FINTRAC).

Thank you for contacting the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Canada’s independent agency responsible for the receipt, analysis, assessment and disclosure of information in order to assist in the detection, prevention and deterrence of money laundering and the financing of terrorist activities in Canada and abroad.

I am writing further to your email of July 16th, 2020, wherein you requested clarification regarding the sharing of suspicious transaction reports (STRs) submitted to FINTRAC.

As you know, section 8 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) states that no person or entity shall disclose that they have made, are making, or will make a report under section 7, or disclose the contents of such a report, with the intent to prejudice a criminal investigation, whether or not a criminal investigation has begun.

The PCMLTFA sets out a regime in which the information contained in financial transaction reports sent to FINTRAC (including STRs) is protected from disclosure except in very limited circumstances. The Act also includes specific provisions aimed at protecting the personal information under FINTRAC’s control. For example, as you may be aware, the PCMLTFA is founded on a prohibition on disclosure (s. 55(1), PCMLTFA). Any disclosure of information or intelligence by FINTRAC must fall under one of the exceptions to this prohibition. Outside of these exceptions, FINTRAC is prohibited from disclosing the contents of financial transaction reports, or even acknowledging their existence.

While reporting entities (REs) are not subject to the same prohibitions, FINTRAC strongly believes that STRs should be regarded as highly sensitive documents, given the role FINTRAC plays in the fight against money laundering (ML) and terrorist activity financing (TF) in Canada, and the fact that STRs are a key source of FINTRAC’s intelligence holdings. From FINTRAC’s perspective, it is not in the public interest for REs to disclose financial transaction reports and the information contained therein. Even beyond this, the collection or disclosure of financial transaction reports, including STRs, without a valid purpose and authority, may infringe on legislated privacy protection obligations. Almost all information within financial transaction reports is personal information about an identifiable individual and is considered financial intelligence by

FINTRAC, collected for the sole purpose of reporting to FINTRAC. The potential harm that could occur from the disclosure of the information in these financial transactions reports is great, and includes compromising: (1) police and national security investigations that are both ongoing or could be undertaken in the future; (2) sources of the information/intelligence within the reports, placing those sources at risk of retaliation; and (3) FINTRAC’s compliance activities, given that data provided by REs is always provided in confidence and that confidence is expected to be maintained by all parties. FINTRAC relies on the information included within STRs to support disclosure of financial intelligence to police and other law enforcement and national security organizations, in the interest of detecting, preventing and deterring ML and TF.

Therefore, while your client (MSB) is not prohibited from sharing the STRs it has submitted to FINTRAC with its service provider (Bank/CU), unless it is with the intent to prejudice a criminal investigation, strong consideration should be given to the above.

If you would like a PDF copy of the complete question and policy position for your due diligence files, or to provide to an external party that is requesting copies of your STRs, or information about their content, you can download it here.

Response from FINTRAC – Re_ Sharing Copies of STRs_ASTRs

A version of this Q&A is also now posted on FINTRAC’s website (PI-10662).

The response from OPC, in contrast, was underwhelming. In essence, they will investigate specific complaints, but they will not issue advanced rulings. That said, if any service provider is insisting that copies of STRs must be shared with them, a complaint to the OPC may be an option.

Response from the Office of the Privacy Commissioner of Canada – INFO-084075

Need a hand?

If you have AML or privacy-related questions, we can help. You can get in touch using our online form, by emailing info@outliercanada.com, or by calling us toll-free at 1-844-919-1623.

Amended AML Regulations June 10, 2020 – Redlined Versions

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.

Redlined versions of all the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations are listed below for download.

These documents are not official versions of the regulations. Official versions can be found on the Government of Canada’s Justice Laws Website.

Regulations Amending the Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act

Please click the link below for downloadable PDF file.

Regulations Amending the Regulations Amending Certain Regulations Made Under the Proceeds of Crime July 2019 – Redlined_June 2020

Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations

Please click the links below for downloadable pdf files.
PCMLTF_July_2019_Redlined_Full_July_2019 – Redlined_June 2020

Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations

Please click the links below for downloadable pdf files.
PCMLTF_Suspicious_Transaction_Reporting_Regulations_July_2019 – Redlined_June 2020

Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations

Please click the link below for a downloadable PDF file.
PCMLTF_Registration_Regulations_July_2019 – Redlined_June 2020

Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations

Please click the link below for a downloadable pdf file.
PCMLTF_Administrative_Monetary_Penalties_Regulations_July_2019 – Redlined_June 2020

Proceeds of Crime (Money Laundering) and Terrorist Financing Cross-Border Currency and Monetary Instruments Reporting Regulations

Please click the link below for a downloadable pdf file.
PCMLTF_Cross-Border_Currency_and_Monetary_Instruments_Reporting_Regulations_July_2019 – Redlined_June 2020

Need a Hand?

Whether you need to figure out if you’re a dealer in virtual currency, to put a compliance program in place, or to evaluate your existing compliance program, we can help. You can get in touch using our online form, by emailing info@outliercanada.com, or by calling us toll-free at 1-844-919-1623.

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