Anti-Money Laundering
Consulting Services & Strategies

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AML Compliance Program Development

Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations (Regulations), Canadian reporting entities are required to have an anti-money laundering (AML) & counter terrorist financing (CTF) compliance program that consists of these elements:

  1. A Compliance Officer:  you must appoint a person who is ultimately responsible to develop and maintain your AML and CTF compliance program. While there are no specific requirements in terms of education or designations, it is important that the person is qualified, and has the right authority within your organization to be effective in their role.
  2. Policies and Procedures:  these are documents that describe your responsibilities under the law, and what you are doing to meet them.
  3. A Risk Assessment:  this is a document that analyzes the risk that your business could be used to launder money or finance terrorism, and the things you are doing to prevent that from happening (which are called controls).
  4. Training:  all employees, agents, and mandataries must receive AML and CTF training on an ongoing basis. This is generally interpreted to mean that training should be conducted at least annually.
  5. AML Compliance Effectiveness Reviews:  this is like an audit for compliance. It involves formal testing and reporting. The results, and your remediation plan for any deficiencies, must be reported to your Senior Officer within 30 days. The review itself must be completed at least every two years.

Each element of your compliance program must be documented. Outlier can assist you in ensuring that any/all of these elements are created, well documented, and specific to your business model. Outlier develops AML and CTF compliance programs for financial entities (such as banks and credit unions), money services businesses (MSBs), dealers in precious metals and stones (DPMSs), securities dealers, and real estate companies.

Where it is mutually agreeable, most AML and CTF compliance program development work can be completed on a fixed-fee basis (meaning that you know exactly what you’ll pay before we start work).