Blog | Outlier Compliance Group

Ministerial Directives Related to Iran & LVCTRs

Rodney MacInnes, CRO & AML Compliance Ninja on June 29, 2023

There have been a number of conversations floating around about FINTRAC Large Virtual Currency Transaction Reporting (LVCTR) obligations as it relates to transactions involving Iran, and potentially involving Iran, under the current Ministerial Directive (MD). While this is not a new requirement (LVCTRs were effective June 1, 2021 and the original MD became effective July 25, 2020), there has been clarification provided with regards to reporting, and what activities trigger which reports.

Proposed 2023 AML Changes: Mortgage Lenders and Armoured Car Services

David Vijan, Co-Founder & CEO on March 1, 2023

Background

February seems to be the month for proposed legislative changes.

On February 18, 2023, draft amendments to the regulations under the Proceeds of Crime Money Laundering and Terrorist Financing Act (PCMLTFA), and a net-new draft regulation, were published in the Canada Gazette. If you’re the type that likes to read original legislative text, you can find it here. We (thanks Rodney) also created a redlined version of the regulations, with new content showing as tracked changes, which can be found here.

The Proposed Retail Payment Activities Regulations

David Vijan, Co-Founder & CEO on February 16, 2023

Background

On February 11, 2023, the proposed Retail Payment Activities Regulations were published in the Canada Gazette. This is to support the Retail Payment Activities Act (RPAA) which was released under Bill C-30 and received royal assent in June 2021. The Retail Payment Activities Regulations are required to bring the RPAA into force.

New Illegal Wildlife Trade Indicators

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on January 31, 2023

FINTRAC has published a new Operational Alert on the Illegal Wildlife Trade.

The alert includes diagrams of known fund flows, both into and out of Canada (though the latter is most common). Three categories of indicators are included:

Suspicious Transaction Reporting Updates

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on December 20, 2022

FINTRAC has published updated resources related to upcoming changes to suspicious transaction reports (STRs) on its Draft Documents page. This includes updated draft guidance on STRs, expected to come into force in September 2023.

New Terrorist Financing Indicators

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on December 15, 2022

FINTRAC has published updated indicators related to terrorist activity financing.

These are subdivided into three broad types of violent extremism:

religiously motivated violent extremism (RMVE),
politically motivated violent extremism (PMVE), and

First AML Compliance Effectiveness Review Timing

Rodney MacInnes, CRO & AML Compliance Ninja on October 14, 2022

As a company that gets to work with a lot of startups, and existing companies entering the Canadian market, we get to help folks understand the regulatory landscape in Canada. One of the required elements of a Canadian compliance program is an AML Compliance Effectiveness Review. These reviews must be completed every two years at a minimum. You can think of it like an audit, but for compliance.

9 Years of Entrepreneurship

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on September 1, 2022

If you had told me ten years ago that I would be in the longest-running position in the history of my career, I wouldn’t have believed you. Back then, I was unhappy for various reasons, and while I had started to think about what I really wanted from my work life, I had yet to take some of the big steps to get there. I won’t go into the gory details of where I was or the situations that weren’t working for me. Suffice it to say that there was a lot that wasn’t working, and I didn’t know how to fix it… but I had some ideas.

FINTRAC MSB Registration Expired?!?

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on August 2, 2022

FINTRAC Registration

Over the past few months, we have heard from several money services businesses (MSBs) that have experienced issues in renewing their MSB registrations with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). In most cases, these issues are easily resolved. However, if MSB registration issues are not addressed promptly, administrative monetary penalties (AMPs) or criminal charges may ensue.

Outlier Compliance Group welcomes Karene Lewis!

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on July 25, 2022

The Outlier Compliance Group team is thrilled to welcome our newest member, Karene Lewis!

Karene brings deep banking (including credit union) and money services business (MSB) experience.

Karene’s Bio

Karene joins the Outlier team with more than 15 years of experience in the financial services sector; over 10 years of experience working in the Credit Union sector; over eight years of working experience building relationships with MSBs and PSPs, and enhancing and managing compliance programs for a variety of regulated entities.

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