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FINTRAC Releases Policy Positions

Amber looking at laptop FINTRAC screenFrom the time that we launched, we at Outlier have believed strongly that information should be free.   When we have received information from regulators or other government agencies that we believe could be useful to our friends and clients, we’ve posted that information on our blog, making the information accessible without cost. This has lead us to make inquiries with agencies including the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Most recently, we’ve requested access to all of the policy positions that FINTRAC has provided from 2008 to the present date. As a consequence of this request, FINTRAC will be releasing this data to the public in the near future.

You can read FINTRAC’s confirmation letter here.

00047 – signed reply letter

The Big Disclaimer

The information that follows is based on our requests and conversations with FINTRAC. We are not lawyers and do not present any of our content as legal advice. If you feel that we’ve missed something vital, or misrepresented an important point, please feel free to contact us and we’ll do our best to correct it.

FINTRAC Has Gone Public

Policy positions are statements that FINTRAC has made about how the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its enacted regulations (Regulations) should be applied. These are the “opinion” or “position” of the regulator (similar to the guidelines released by FINTRAC), intended to assist reporting entities in complying with the law. Like guidelines, they are subject to change and do not carry the force of law – but do have the ability to be powerful tools for reporting entities.

We applaud FINTRAC’s decision to make this information available to the public and look forward to reviewing the publications!

You can see the initial publication here (scroll down to the FINTRAC Policy Interpretations section).

What It Means For Your Business

Reporting entities should review the policy positions when they are released and look for guidance that can be applied in refining their anti money laundering (AML) and counter terrorist financing (CTF) compliance programs.  FINTRAC has confirmed that “sanitized, non-repetitive, versions” of the policy interpretations positions will be made public on an ongoing basis.  Historical policy interpretations (from 2008 to the present date) are expected to be published via FINTRAC’s website in December this year.

Obsolete Policy Positions

We have received as part of our initial information request a list of policy positions that FINTRAC considers to be obsolete (no longer accurate or relevant). While these are less useful to most reporting entities than current policy positions, it may be useful for reporting entities to review this content to determine whether they are relying on information that FINTRAC no longer holds true. You can access this information using the link below.

Obsolete Policy Positions

Need a Hand?

If you have questions about AML or CTF compliance, including what a policy position might mean for your business, please contact us for more information.

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