• Suspicious transactions reporting
  • Industry and industry subsectors required/ not required to report suspicious transactions to FINTRAC
  • Standard of Care: Steps that can be taken to determine if you have “reasonable grounds to suspect” that a transaction is related to ML or TF
  • Standard of care articulated by FINTRAC / Industry standards of care
  • Sector specific indicators
  • What does reporting “as soon as reasonably practicable mean?
• EFTs
• Travel rule
• Large cash

As rules change so too do the various techniques used to launder money or finance terrorism. This session will look at recent changes in the rules and resulting changes in typologies and new and emerging red flags to be aware of.

• Increased scope to prosecute money laundering under the Criminal Code with the addition of “recklessness” in moving money on someone else’s behalf while being aware that there is a risk of money laundering
• Mandatory public disclosure of administrative monetary penalties
• KYC requirements relaxed for non-face-to-face transactions – original documents no longer required just authentic, valid and current copy
• IROC updated guidance for securities dealers
• Money laundering indicators for casinos to assist casino businesses in identifying and reporting suspicious transactions that may be related to money laundering activities
• Need for reporting entities to align compliance programs and processes to meet regulatory expectations
• Need to update legacy systems

• Shape and form of registries
• FINTRAC’s amended position on confirming the accuracy of beneficial ownership information
• Best practices to ensure the accuracy of the information obtained?
• Documentary sources
• Non-profits and trusts
• Methods to verify the identify of the most senior management officer
• What if no individual owns or controls 25% or more of a corporation or trust?
• Requirements to keep beneficial ownership information up to date

• FINTRAC’s definition of MSBs
  • Foreign MSBs
  • Virtual currency dealers
• Client identification requirements -authentic, valid and current
• Reporting requirements
  • Suspicious transactions
  • Large Cash transactions
  • EFTs
• Record keeping
• Ongoing monitoring
• Recent changes
• Record keeping
• Exceptions to beneficial ownership determination
• The BC Land Ownership Transparency Act: the first such registry to be fully compliant with best practices

Massive questionable transactions flowing through B.C. casinos, the doubling of suspicious cash investigations in Ontario casinos and suspected links to international drug cartels in both provinces have led to new regulatory requirements for casinos and the banks doing business with them.

• What qualifies as a casino under the Act?
• Overview of key compliance program requirements
• Provincial requirements issues
• Reporting requirements
• Record keeping requirements
• Assessing penalties and risks of non-compliance

The Risk-Based Approach (RBA) requires reporting entities to conduct assessments of their exposure to money laundering and terrorism financing risk using a number of prescribed criteria. This session will cover:

• FiINTRAC’s expectations
• The new obligations that result from the new regulatory requirements
• The risk based approach cycle
• Risk assessment
• Mitigation
• Client identification, beneficial ownership, business relationship information in accordance with assessed level of risk
• Ongoing monitoring of transactions and business relationships