FINTRAC’s statements about AML during Covid stress that the compliance show must go on… and with good reason. Criminals are clearly taking advantage of perceived vulnerability to perpetrate pandamic-related fraud and related money laundering. STRs are first priority, towards FINTRAC’s unrelenting focus on compliance for intelligence.
While FINTRAC exams are currently suspended, FINTRAC’s expectations for compliance effectiveness reviews have not changed. A well planned and executed review not only prevents surprises for future examinations, but it also assists in preparation for known changes to legislation and guidance.
Remote work is not a barrier to a great review – and it might be the perfect time for you to evaluate your AML program and retool while client-facing activities have abated.
The AML Shop is well-practiced at conducting its procedures for a review from a distance – in much the same manner as FINTRAC conducts its desk reviews. We apply our insights from participation in dozens of FINTRAC examinations, from their guidance and examination manual, from the practices of your peers, and from international standards. Following their lead, our procedures are focused on risk and ongoing monitoring, with detailed and deep analytics for high-risk clients and transactions to test effectiveness.
In almost all instances, our review begins with an in-depth interview with the Chief Anti-Money Laundering Officer and a detailed information request. We exchange documents using secure services with Canadian-only storage with guaranteed privacy. Records-review can be conducted with read-only auditor access to the back-office and transaction monitoring, or through extracts. And our interviews can be planned around the schedules of your team, service providers, and agents.
Most reviews can be conducted in four to six weeks. We have many clients taking advantage of this unique time we find ourselves in. There’s still plenty to do to remain fully compliant yet many businesses don’t have the resources to conduct these reviews themselves. We’re your AML partners every step of the way. Starting with a compliance effectiveness review is a great way to meet you and your team and learn about your business while ensuring you are fully compliant. Contact Matt McGuire at matt@theamlshop.ca.