The global anti-money laundering (AML) and counter-
terrorist financing (CTF) compliance landscape has been 
changing at a phenomenal rate over the last 10 years. 
AML/CTF has moved from being a mere second thought 
in the minds of Boards of Directors at leading financial 
firms, to an issue that now drives business decisions as 
organizations work to find their way through the myriad 
of regulation to meet their obligations. 

Enforcement in many parts of the world is strict 
and aggressive. Companies, as a result, face the 
unpleasant risk of media headlines if compliance 
with AML/CTF requirements is found to be wanting. 
Besides the financial cost of potentially record fines, 
damage to reputation is a very real and significant 
cost. Witness the extraordinary press coverage and 
other attention that has accompanied record fines 
being imposed on global banks for breaches of AML 
regulations, particularly in the US and the UK. In one 
case, a fine of US$1.9 billion was levied by the US 
Department of Justice to settle a money laundering 
case as a result of alleged AML regulatory breaches 
and inadequate controls. A quick scan of the reputation 
impact shows the unenviable attention in the world’s 
media as well as the other potential fall-out related to 
litigation, hearings and remediation costs. 

But how does this all relate to Canada? It is important 
to set the scene in order to see how, to meet 
international expectations, Canada has had to up 
its game in the fight against money laundering and 

terrorist financing. One might argue that since the 
maximum administrative monetary penalty that the 
Canadian regulatory body, Financial Transactions and 
Reports Analysis Centre of Canada (FINTRAC), has 
the capacity to issue is $500,000, that the financial 
cost of lax compliance does not justify the expense of 
a robust, thorough and complete AML/CTF program. 
However, Canadian-based organizations are operating 
in an environment where increasingly, non-compliance 
will not be tolerated. And, the real cost of exposure of 
non-compliance will be greatly in excess of regulatory 
penalties as a result of reputational damage, potential 
litigation and other remedial costs. As a result, it is in 
the interest of companies to protect their reputations 
and profit margins by establishing and maintaining 
effective AML/CTF regimes. 

But the situation in Canada is anything but static. 
Tides are turning; the general consensus is that it is 
only a matter of time before the prevalence and size 
of administrative monetary penalties increases within 
Canada. In addition, we are seeing increased focus on 
regulatory enforcement. Our clients have responded 
to the changing environment with increasing requests 
for effectiveness testing of AML/CTF regimes, 
implementation of training programs, general support 
for identifying money laundering and terrorist financing 
concerns and recommending controls to mitigate 
this risk. They are responding to the serious call for 
accountability required by regulatory authorities.

is a Manager in KPMG’s Forensic practice where she serves as a specialist in Anti-Money 
Laundering Services. She joined KPMG in May 2011 and has worked from KPMG’s London, 
England and Toronto offices. Candice has been involved in a variety of projects relating to 
anti-money laundering (AML) processes and procedures including assisting clients with 
regulatory enquiries, remediation, and independent effectiveness testing. Prior to KPMG, 
Candice worked within the financial services industry specifically aligned to AML, holding 
compliance positions within two global investment banks.

Candice Ramlogan

Contact:  

candiceramlogan@kpmg.ca 

or

 (647) 777- 5333

© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms 
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

At Risk

 

 

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 Volume 7, No. 1 

 

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