Day One : Thursday, August 20, 2020

10:00 EDT

15 min

Welcome and Opening Remarks from the Chair

10:15 EDT

45 min

What are reasonable grounds to suspect (RGS)?

  • Operationalizing RGS within your compliance program
  • Overview of thresholds for suspicion
  • Production orders – Do they constitute Automatic Suspicion
  • What to include in your policies and procedures

11:30 EDT

45 min

Steps / Measures for determining if you have “Reasonable grounds to suspect” (RGS)

  • Proper investigative techniques
  • Assessing the facts and context surrounding the suspicious transaction
  • Investigative timelines
  • Follow-up on previous STR’s
  • Articulation – How to protect your decisions against regulatory oversight.

12:15 EDT

45 min


13:00 EDT

30 min

How Suspicion May Arise

  • Linking ML / TF indicators to your assessment of facts and context
  • Examples of how suspicion may arise
  • Prioritizing the submission of the STR
  • Covid Guidance
  • Terrorist Financing
  • Public Private Partnerships

13:30 EDT

30 min

FINTRAC and Self-Assessment, Quality Control, Update on Penalties

  • How does FINTRAC assess your compliance with the obligation to submit STRs?
  • How can you assess your own compliance with the obligation to submit STRs?
  • What is effective quality control/oversight
  • Update on Administrative Monetary Penalties

14:00 EDT

15 min

Case Studies and Reporting Deficiencies to Avoid

  • Examples and case studies of how suspicion may arise
  • Common STR deficiencies to avoid

14:15 EDT

25 min


14:40 EDT

80 min

Your Training Program

  • How does FINTRAC assess your compliance training obligations?
  • Establishing and implementing a comprehensive and effective training program
  • Developing and maintaining written ongoing compliance training program for employees, agents, and others authorized to act on your behalf

16:30 EDT

End of Day One