March saw publication of the first 2023 administrative monetary penalties ($676,500) from FINTRAC.
Identified was:
Failure to develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)
Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c)
Failure to institute and document the prescribed review – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(f)
Failure to report suspicious transactions – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 7
With this reminder, are you confident your AML/ATF program will withstand scrutiny?
Please reach out if you want to discuss further.
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