As previously noted, the amount of information
to be provided in reports to FINTRAC has been
expanded and the schedules have been reorganized, but that’s too big a topic for this article.
Name and Shame: Publication by FINTRAC of all
administrative monetary penalties was made
mandatory in amendments to the PCMLTFA in
June 2019. Previously the legislation was
permissive but did not require publication.
Included are compliance agreements between a
reporting entity and FINTRAC to resolve a Notice
of Violation. Public notices of violations are kept
on FINTRAC’s web site for 10 years.
Beneficial Ownership Disclosure: IIROC’s new
plain language rule book has been approved by
the CSA and will be implemented in June 2020.
It changes the threshold for obtaining beneficial
ownership information from the current 10% to
25% to make it consistent with the PCMLTFA
It’s a pity that IIROC couldn’t find a way to
implement that one provision right away instead
of waiting another 10 months.
Monthly Reporting: The monthly reporting
requirements for sanctioned persons, including
nil reports, have been greatly reduced, now
applying only to terrorists and terrorist organizations named under the Criminal Code and those
sanctioned under the Justice for Victims of
Corrupt Foreign Officials Act (Sergei Magnitzky
OSFI Stops Publishing Lists: Because of the
reduction in monthly reporting, OSFI stopped
publishing its lists of sanctioned individuals. The
requirements for financial institutions to check
on them and report any accounts identified
haven’t changed though, and in any case, OSFI’s
lists did not provide full coverage on that front.
To fill the information gap, Canchek has prepared
a plain version of what the PCMLTF Regulations
and the suspicious transaction reporting
regulations will look like when all the changes are
implemented. We also have a version highlighting
material changes – not exactly a blackline
because of the movements and merging of
sections – but something that will allow
interested parties to see what’s new including
what we consider changes in nuance.
To obtain a copy, please contact:
The cost is that if you aren’t already a Canchek
customer, we will take the opportunity to tell
you why you should be.
Contact us at sales
for a demo of Canada’s AML solution
Organiza ons face increased regulatory demands and bear the
burden of checking, monitoring and disclosure, all the while
remaining compe ve. Canchek® Risk Intelligence serves the
helping you uncover
hidden risks in business and human networks. Everything you used to
get from OSFI, and A LOT -
under Canadian law do not end there.
CEASE TRADE ORDERS