We recently had a discussion with a potential client, a "Money Services Business", who was looking to manage their compliance Program to meet Fintrac requirements.
We discussed the Compliance Program requirements as specified under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations that apply to all reporting entities.
The key elements:
appointing a compliance officer, responsible for implementing the program
developing and applying written compliance policies and procedures - kept up to date and approved
conducting a risk assessment of your businesses - to assess and document the risk of a money laundering offence or terrorist activity financing offence occurring in the course of your activities.
developing and maintaining a written, ongoing compliance training program for employees, agents and others
instituting and documenting a plan for the ongoing compliance training program and delivering the training
instituting and documenting a plan for a review of the compliance program for the purpose of testing its effectiveness, and carrying out this review every two years at a minimum
Ethidex can assist with implementing and managing the operation of the Compliance Program by making use of:
Regulatory content modules - addressing AML/ATF and Privacy (as well as others)
Software as a service with workflow to assist with assessment and documentation.
If you would like to discuss further, please reach out.