Oversight by regulators is becoming
more active and focused. Recent
experience has indicated that Canadian
companies are facing greater AML/
CTF regulatory scrutiny which is
expected to continue, warranting
industry participants’ concerns in
relation to the new regulatory changes.
Our exposure to recent regulatory
letters or AML/CTF findings indicate
a more aggressive regulatory posture
compared to the past.
Compliance in
the future
As indicated, Canada continues to
advance its AML/CTF regulations and
enforcement efforts closer to current
international expectations. However,
even with the proposed changes to
the PCMLTFA, there will be continuing
differences in certain requirements
in Canada in comparison to some our
major trading partners. For example:
•Canada does not require
independent documentary
evidence of a customer’s
shareholding structure.
•Canada does not require validation
of the source of funds for all
customers (only required for high
risk customers where enhanced
due diligence is performed).
•Source of wealth of customers or
their significant beneficial owners
is not commonly explored in
Canada to ensure they are the true
individuals behind the customer
for whom the relationship is
established. This procedure is
significant because it mitigates
the risk of omitting nominee
shareholders or third parties being
appointed.
As indicated,
Canada
continues
to advance
its
AML/CTF
regulations and
enforcement
efforts closer
to current
international
expectations
.
© 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.
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At Risk
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Volume 7, No. 1