Canada’s AML Effectiveness Reviews

One of the requirements under Canada’s anti-money laundering (“ML”) and anti-terrorist financing rules (“TF”) (together, “AML”) is for securities firms to have a bi-annual AML effectiveness review. What is an AML effectiveness review? An AML effectiveness review is an evaluation that must be conducted at least every two years to test the effectiveness of a firm’s compliance program. The review must be started no later than two years from the start of the firm’s previous review. The purpose of an AML effectiveness review is to determine whether a firm’s compliance program has gaps in its AML program. What is Registrant Law’s AML effectiveness review? At Registrant Law, we offer competitively priced AML effectiveness reviews.

The scope of Registrant Law’s AML effectiveness review would be as follows:

1. review a sample of your firm’s records to assess your:
• client identification procedures;
• suspicious transactions reporting to FINTRAC;
• ongoing monitoring;
• procedures for dealing with high-risk clients; and
• record keeping procedures;

2. review your firm’s:
• risk assessment;
• AML policies and procedures;
• training program;

3. interview with appropriate staff; and

4. review the role of the CCO/CAMLO.

Registrant Law would be pleased to discuss your AML effectiveness review with you. Please contact Nancy Mehrad at nancy@registrantlaw.com. This article is an overview only and does not constitute legal advice. It is not intended to be a complete statement of the law or the proposed regulations. You should not act upon the information in this article without a thorough examination of the law or proposed regulations as applied to the facts of your situation.