• Overview of FINTRAC’s assessment approach
• What is FINTRAC’s approach in assessing the amended regulations
• How harm is factored into our approach and outcomes
• Summary on FINTRAC’s approach post CIF
• Highlight of successes and challenges/gaps we are seeing across some of the sectors

With antiquated corporate registries that have limited search functionality and disclose little about ownership, and vast shortcomings in Canada’s financial crime detection and enforcement mechanisms, Canada is among the most opaque jurisdictions globally. it is possible to set up and operate companies from abroad with little risk of being held accountable for wrongdoing.

• The need for transparent company data
• April 2021 proposal to implement a public beneficial ownership registry by 2025
• Shell companies as “the getaway cars of financial crime.”
• Characteristics making Canadian entities attractive as shells
• Why The Limited Partnership (LP) is particularly vulnerable to exploitation for transnational financial crime
• Intermediaries and Intermediary advertisements
• The power of an open registry: Case studies using U.K data
• Other required changes to company laws

Key findings from the Cullen Commission final report, which was made public on 15 June 2022

• New initiatives and measures to achieve beneficial ownership transparency, at the national and pan-Canadian level, as well as BC’s Land Owner Transparency Registry
• Law enforcement and regulatory reforms and issues to improve the response to money laundering risks and vulnerabilities
• Public interest in, and awareness of, money laundering issues

Dealers in virtual currency (VC) have been regulated as money services businesses (MSBs) since 2020. Dealers in VC that hold custody of VC on behalf of clients are also regulated as securities dealers. While the sector faces some unique challenges, it has also risen to the challenge of providing high quality actionable information for law enforcement. The panel will discuss:

• Different VC business models and their respective risk
• Unique VC-related transaction monitoring tools, such as blockchain analytics tool
• Crime-related trends
• Need for threat intelligence
• Need for statement of risk appetite

Financial entities, money service businesses, foreign MSBs and casinos are subject to the Travel Rule. The travel rule is the requirement to ensure that specific information is included with the information sent or received in an EFT or a VC transfer. Information received under the travel rule cannot be removed from a transfer.

• What information must accompany an EFT or VC transfer?
• What if an EFT or VC transfer does not include the required information?
• What are “reasonable measures” to obtain the missing information?
• Requirement to describe “reasonable measures” in writing in policies and procedures
• Risk-based written policies and procedures for what to do when reasonable measures are not effective

• What are reasonable grounds to suspect (RGS)
• Steps/Measures for determining if you have “reasonable grounds to suspect” (RGS)
• How suspicion may arise
• FINTRAC and self-sssessment, quality control, update on penalties
• Case studies and reporting deficiencies to avoid

• What are some of the similarities and differences between an AML compliance investigation and a police investigation?
• Difference between intelligence, information and evidence
•  A FINTRAC disclosure is an “intelligence product” based on information provided by reporting entities. What needs to be done to action this as evidence and how can REs complete more relevant STRs?
• What are some of the obstacles when conducting international and high level money laundering / asset forfeiture investigations?
• What does an ideal public private partnership mechanism look like?
• Future crime – crypto or cash / combination / source of funds and predicate crimes