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Fixed Fee AML Reviews for the Real Estate Sector

No Hassle, Fixed Fee AML Compliance Effectiveness Review Pricing

All real estate developers, brokers and sales representatives are required to have AML Compliance Effectiveness Reviews at least every two years. These reviews involve a review and assessment of your compliance program and operational testing. Real estate developers, brokers and sales representatives will receive a formal review report, and Senior Management must provide signoff on the final report within 30 days of the day it’s issued. While Canadian legislation permits self-reviews, reviews must be independent, something harder to do at small to medium sized firms. The reviewer must be sufficiently qualified. At a minimum, each reviewer must:

  • Demonstrate sufficient understanding of the Canadian regulatory context;
  • Have sufficient experience in conducting AML Compliance Effectiveness Reviews in Canada; and
  • Have maintained up-to-date training and professional qualifications; including, but not limited to, the Certified Anti-Money Laundering Specialist designation.

To make budgeting easier for Canadian real estate developers, brokers and sales representatives, we’re introducing no hassle pricing. To calculate where you fall on the chart, just add up the number of employees and agents you have.

Number of Employees & Sales Agents* AML Compliance Effectiveness Review Price
1 – 50 6,000
51 – 100 7,000
101 – 150 8,000
151 – 200 9,000
200+ Please Call

All prices are subject to applicable taxes. Additional fees apply for staff travel and administration related to the sorting of paper documents (where applicable).

*If you have part-time or seasonal employees, count two part-time employees as one employee. Include business owners who are active in running the business as employees. Count each agent location as one employee. If you’re not sure about the calculation, feel free to contact us.

Coast to Coast to Coast

Our Canadian team is here to serve in all parts of Canada. Given the current COVID-19 pandemic, and to keep costs low, we are currently conducting reviews remotely. To do this, we will review electronic copies of your compliance program and data.

Disclaimers

Outlier cannot be considered an “external reviewer” if we have designed your compliance program or conducted annual training with your staff. Most banking services providers require that you have an external reviewer. Some banking services providers also have specific lists of reviewers whose work they will accept. Please check with your banking services provider to ensure that our review will be acceptable for their purposes.

Need a Hand?

If you’re ready to schedule a review or would like more information, please contact us.

Sanctions This Week: July 25th – 29th, 2016

 

OSFISanctions Pic

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released four updates last week.  One update was related to the publication of Cuba-related Frequently Asked Questions (FAQ), covering some of the recent changes made to the sanctions that had previously been placed on Cuba.  Other updates included the removal of 12 individuals from the Counter Terrorism Designations List, the issuance of a Finding of Violation and the publication of Iran General License J.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The update to the Cuba-related FAQs was for the issuance of a new FAQ (#38) and a revision of an existing FAQ (#39), relating to certain information collection and recordkeeping requirements for persons subject to U.S. jurisdiction who provide authorized carrier or travel services to or from Cuba for specifically licensed travelers.

The update to the Counter Terrorism Designations List included the removal of 12 individuals of Libyan origin who are currently residing in the UK.

The Finding of Violation was issued to Compass Bank, which uses the trade name BBVA Compass, for violations of the Foreign Narcotics Kingpin Sanctions Regulations. From June 12, 2013 to June 3, 2014, Compass maintained accounts on behalf of two individuals on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”).

The final update of the week was related to OFAC issuing “General License J”, authorizing the re-exportation of certain civil aircraft to Iran on temporary sojourn and related transactions.

See the Cuba-related FAQ update on OFAC’s website.

See the Counter Terrorism Designations List update on OFAC’s website.

See the issuance of a Finding of Violation to Compass Bank on OFAC’s website.

See the Iran General License J details on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: July 18th – 22nd, 2016

OSFIOutlier3_032

On July 18th and 22nd, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC’s) Al’Qaida and Taliban regulations updates to the sanctions list, deleting one individual and amending another.

The individuals are subject to the assets freeze, travel ban and arms embargo set out in paragraph 2 of Security Council resolution 2253 (2015) adopted under Chapter VII of the Charter of the United Nations.

The review of the individual who was deleted from the list was triggered by regularly scheduled updates.  However, no additional information was available regarding the justification.

The amendment of one individual’s information included the following:

  • A physical description;
  • The confirmation of the most recent position held within the Taliban, as of April 2015; and
  • That they are currently involved in drug trafficking and operate a heroin laboratory in Afghanistan.

See the July 18th update on the United Nations (UN) website.

See the July 22nd update on the United Nations (UN) website.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released three updates last week.  One update was related to the addition of three individuals to the Counter Terrorism Designations list.  The second update was related to the addition of multiple individuals and entities to the Syria and Non-proliferation Designations lists.  The final update last week was to the Kingpin Act and Panama-related Frequently Asked Questions (FAQs) regarding General Licenses.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The changes to the Counter Terrorism Designations list included three individuals of different nationalities, Saudi Arabia, Egypt and Algeria, though all have been linked to Al Qa’ida.

The update to the Syria Sanctions list included eight individuals, all of whom are Syrian.  The seven entities, which range from construction, to finance to manufacturing industries and vary in location, which include:

  • Syria;
  • Saint Kitts and Nevis;
  • Cyprus;
  • UAE; and

The update to the Kingpin Act and Panama-related FAQs are specific General License 5B and 6B

See the Counter Terrorism Designations list update on OFAC’s website.

See the Syrian and Non-proliferation Designations lists update on OFAC’s website.

See the Kingpin Act and Panama-related General License FAQs update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: July 11th – 15th, 2016

OSFIOutlier3_036

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released one update last week.  The update was related to the addition of two Russian individuals who were added to the Counter Terrorism Designations list.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

No other information was available on the individuals who were added.

See the Counter Terrorism Designations list update on OFAC’s website.

See OFAC’s Recent Actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: July 4th – 8th, 2016

OSFISanctions Pic

On July 5th, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC’s) Al’Qaida and Taliban regulations update to the sanctions list, removing one individual.

Individuals who are included in the list are subject to the assets freeze, travel ban and arms embargo set out in paragraph 2 of Security Council resolution 2253 (2015) adopted under Chapter VII of the Charter of the United Nations. The individual delisted was decided following a review, initiated by a request that was submitted to the Ombudsperson.  The individual is a German national and has been imprisoned in Germany since 2007.

See the update on the United Nations (UN) website.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released three updates last week.  The first update, released on July 5th, 2016 was related to the settlement of a potential civil liability for apparent violations of the Iranian and Sudanese transactions and sanctions regulations.  The second update was related to the addition of multiple North Korean individuals and entities to the North Korean Designations List.  The final update was further clarification to the new Cuba-related Frequently Asked Questions (FAQ).

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The settlement on July 5th for apparent violations of the Iranian and Sudanese sanctions was levied against Alcon Laboratories, Inc., Alcon Pharmaceuticals Ltd., and Alcon Management SA.  In the course of the investigations, Alcon produced documents and information where it appeared that from August 2008 to December 2011, Alcon violated Iranian sanctions on 452 occasions and Sudanese sanctions on 61 occasions.  Alcon engaged in the sale and exportation of medical end-use surgical and pharmaceutical products from the United States to distributors located in Iran and Sudan without OFAC authorization. OFAC determined that Alcon did not make a voluntary self-disclosure and that the apparent violations were not egregious. The statutory maximum civil monetary penalty amount for the Apparent Violations was $138,982,584 USD and the base penalty amount was $16,927,000 USD.  Ultimately, Alcon paid $1,317,150 USD.

The North Korean sanctions list update included numerous individuals and entities, some of whom are high-ranking officials with titles such as:

  • Director of the Fifth Bureau of the Reconnaissance;
  • Director of the Workers’ Party of Korea Propaganda and Agitation Department; and
  • Minister of People’s Security.

The update to the Cuba-related FAQs were specific to the issuance of two new questions added, #43 and #50, regarding the use of the U.S. dollar in certain transactions.

See the Enforcement Action update on OFAC’s website.

See the North Korea Designations List update on OFAC’s website.

See the Cuba-related FAQ update on OFAC’s website.

See OFAC’s Recent Actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: June 27th – July 1st, 2016

Sanctions Pic

OSFI

On June 27th, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released two updates to the United Nations Security Council’s (UNSC’s) Al-Qaida and Taliban regulations sanctions list, amending 8 individuals and 1 entity.

The individuals are subject to the assets freeze, travel ban and arms embargo set out in paragraph 2 of Security Council resolution 2253 (2015) adopted under Chapter VII of the Charter of the United Nations.

All of the individuals are of different nationalities, but all have connections to Al-Qaida and French terrorist groups.  Some of the individuals have been detained and are currently serving out sentences.  Where others have arrest warrants issued by France, which are currently outstanding.

Go to the OSFI UNAQTR update on the OSFI page.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released three updates last week.  One update was related to the Counter Terrorist Designations list.  The second update was the publication of new Panama-related and Kingpin Act General Licenses and related Frequently Asked Questions (FAQ). The FAQ update is related to recent adjustments made to the sanctions placed on Panama.

OFAC also released the details about the implementation of the Federal Civil Penalties Inflation Adjustment Act, where penalties related to AML failings have increased 150%, the allowable maximum.  The adjustment to the base fine of USD 11,000, has now increased to USD 27,500.  This is based off the Consumer Price Index, and if you are curious about the actual math, see the image below:

OFAC CMP Calculation

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The changes to the Counter Terrorism Designations list included the removal of 11 Somali and Djibouti nationals.  The update also included the addition of one individual of Indian nationality with ties to the entity added, which is a section of Al-Qaida operating within India.

See the Counter Terrorism Designations List update on OFAC’s website.

See the Kingpin Act/Panama-related General Licenses and FAQs update on OFAC’s website.

See the Implementation of the Federal Civil Penalties Inflation Adjustment Act update on OFAC’s website.

See OFAC’s Recent Actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: June 20th – 26th, 2016

 

OSFIOutlier3_032

On June 20th, 2016, the Office of the Superintendent of Financial Institutions (OSFI) released the United Nations Security Council’s (UNSC’s) Al-Qaida and Taliban Regulations (UNAQTR) update to the sanctions list, removing one individual.

The assets freeze, travel ban and arms embargo, set out in paragraph 2 of Security Council resolution 2253 (2015), no longer apply to the individual.  The review pursuant to Security Council resolution 1822 (2008) was concluded on July 30th, 2009, which is almost seven years ago.  For further information about the process for removing individuals and entities from the UNAQTR List, pursuant to a decision by the UN Security Council Committee, may be found in the “Press Releases” section on the Committee’s website.

Go to OSFI’s release of the UNAQTR update on the OSFI page.

Go to the United Nations Security Council Committee’s page on “Delisting”.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week.  One update involved the agreement to to settle potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations.  The second update was the addition of a single individual to the Democratic Republic of the Congo Designations list.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.

The OFAC penalty settlement amount for violations of the Iranian Transactions and Sanctions Regulations was $107,691.30 USD.  The stated violations are as follows:

  • On or about April 15, 2011, the company appeared to have violated the Regulations when it exported 3,600 medical products to its United Arab Emirates distributor with knowledge, or reason to know, that the goods were ultimately destined for Iran; and
  • Additionally, on or about May 27, 2011, the company exported an additional 400 units of the same product to its United Arab Emirates distributor with knowledge, or reason to know, that the goods were ultimately destined for Iran.

OFAC determined that the company voluntarily self-disclosed the apparent violations, and that the company constitutes a non-egregious case. The statutory maximum civil monetary penalty amount for the apparent violations was $1,129,912 USD and the base civil monetary penalty was $159,542.  The settlement amount reflects OFAC’s consideration of the following factors:

  • The company acted willfully by exporting products to its foreign distributor with knowledge, or reason to know, that the exports were ultimately destined for Iran in apparent violation of U.S. law, editing its destination control statement at the request of its distributor, and continuing to conduct business with its distributor after receiving confirmation that the distributor had re-exported the products to Iran;
  • The company’s former CEO and former International Sales Manager knew that the exports were ultimately destined for Iran; and
  • The company did not have a sanctions compliance program in place at the time of the apparent violations.

The company took remedial steps, including the implementation of an OFAC compliance program; and cooperated with OFAC’s investigation and agreed to toll the statute of limitations for a total of 513 days.

See the Enforcement Action Report on OFAC’s website.

See the Democratic Republic of the Congo updates on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: April 25th – May 1st, 2016

OSFIOutlier3_032

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released one update to the Belarus-related Executive Order (EO) 13405 sanction list last week.  The original list was replaced and superseded by the new version, which was effective October 30th, 2015.  The EO names nine (9) entities, who are undermining the democratic processes or institutions in Belarus, as well as any entity or individual who directly, or indirectly, owns or controls 50% or more of the listed entities.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The changes to the Belarus-related EO require any U.S. person(s) engaging in transactions involving, directly or indirectly, any of the entities described above, no later than 30 days after the execution of any such transaction in excess of $50,000, or any series of such transactions exceeding $50,000, to file a report with the U.S. Department of State, Office of Eastern European Affairs.  Reports to be filed, must include:

  • The estimated or actual dollar value of the transaction(s), as determined by the value of the goods, services, or contract;
  • The parties involved;
  • The type and scope of activities conducted; and
  • The dates or duration of the activities.

See the Belarus-related Executive Order update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: April 4th-10th, 2016

OSFI

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates to four sanction lists last week.  The lists that were updated include the following:

  • Counter Narcotics Designations;
  • Iraq-related Designations;
  • South Sudan Designations; and
  • Counter Terrorism designations.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  The changes to the Counter Narcotics list included the removal of Caesar’s Park Hotel in Lebanon, and updates to numerous related entities and individuals.

See the Counter Narcotics, Iraq-related and South Sudan Designation updates on OFAC’s website.

See the Counter Terrorism update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

Sanctions This Week: March 21-27, 2016

Rodney_Money_Clothesline4OSFI

There were no updates released from OSFI this week.

Go to the OSFI lists page.

OFAC

The U.S. Department of Treasury’s Branch, The Office of Foreign Asset Control (OFAC), released two updates last week, related to the Zimbabwe, Counter-Terrorism and Non-Proliferation Designation Lists.  A total of three individuals and six entities were added to the respective lists.  OFAC also released the publication of Iran-related General License I and related FAQs.

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals.  The sanctions target countries, regimes, terrorists, international narcotics traffickers, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the U.S.  All of the additions mentioned above were related to aviation, the names added were either connected to an avionics regime, or were the entity under which they were operating.  As for the Iran-related updates, in order to allow for more efficient processing of applications under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services, OFAC has issued General License I: Authorizing Certain Transactions Related to the Negotiation of, and Entry into, Contingent Contracts for Activities Eligible for Authorization Under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services.  OFAC also updated the Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions under JCPOA.

See the Zimbabwe update on OFAC’s website.

See the Counter-Terrorism and Non-Proliferation update on OFAC’s website.

See OFAC’s recent actions page.

Need A Hand?

We would love to hear from you.  If there are subjects in this post that you would like to know more about, or if you need assistance with your compliance program, please contact us.

 

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