As an EMD you need to have an anti-money laundering (AML) compliance regime with a documented risk assessment.
How good is your risk assessment? And is it well documented? In late 2011, a securities dealer was fined by the Financial
Transactions Reports Analysis Centre of Canada (FINTRAC) for numerous violations including the failure to maintain and
document a risk assessment.
Tax evasion, market manipulation, securities fraud, and money laundering – perpetrators of these crimes are using the
securities industry, and FINTRAC knows it. Since June 2008 FINTRAC has required securities dealers to apply a risk-based
approach to AML compliance, but what does this really mean? It means investing in resources strategically, aligned to your risks.
As a securities registrant, your EMD needs to spend significant resources meeting the needs of various regulators and
your current practices likely include many of the required measures to detect and deter money laundering and terrorist
financing. Are your practices aligned with your identified risks? Do you understand all of your high risk areas?
By Jennifer Fiddian-Green, Partner, Grant Thornton LLP
A Risk Based Approach to your AML obligations
Patrick Ho, Senior Manager, Grant Thornton LLP