Blog | Outlier Compliance Group

EFTs, PSPs & Crowdfunding : Canada’s Changing Regulatory Landscape

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

On April 27^th, 2022 amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) and associated regulations related to penalties for non-compliance were passed. These amendments were unusual, as there was little prior public consultation, no pre-publication for public comment, and they came into force “on publication” (right away). This is particularly unusual, as new business models were included in the money services business (MSB) and foreign money services business (FMSB) categories.

Effectiveness Reviews for Dealers in Virtual Currency

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

Effective June 1, 2020, dealers in Virtual Currency activities were considered as Money Services Businesses (MSBs) and as such, must comply with MSB obligations under amendments made to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). One obligation is to have an AML effectiveness review at least once every two years. MSBs must start their effectiveness review no later than two years from the start of their previous review or in the case of dealers in Virtual Currency, no later than June 1, 2022, the date they were considered to be MSBs under law.

Amendments To The Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations – 2022

David Vijan, Co-Founder & CEO on May 9, 2022

Background

On April 27, 2022 amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations were published in the Canada Gazette. To make reading these changes a little easier, we (thanks Rodney) have created a redlined version of the regulations, with new content showing as tracked changes, which can be found here.

We’re Hiring!

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on April 19, 2022

We’re looking for an AML compliance person. Initially, this is going to be a part-time / backfill role, but we’d love for it to be a permanent role (either part time or full time, depending on the need and fit). We have a team member that will be taking some time off shortly, and we were at the point that we were talking about bringing on another compliance ninja before that. We take bringing on new team members very seriously. We’re a small group, and we work very well together. We’d be lying if we said that “can we just handle the work ourselves?” isn’t something that was brought up (multiple times). You’re reading this posting because we need a very capable human, and maybe that’s you.

Outlier Masking Policy

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

We’ve missed you and we’re looking forward to welcoming you back in person!

As mask mandates lift in Canada and we have face-to-face meetings again, it’s important that we treat one another with dignity and respect. At Outlier, we’re experts in compliance risk management, but we are not medical experts. We respect your right to set your risk tolerance and believe that we should all have the freedom to do so without the need for detailed explanations. Our masking policy reflects this philosophy.

Outlier Compliance Canada Inc. Offering Compliance Services to the Metaverse in Decentraland

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on February 23, 2022

February 23, 2022 Toronto — Outlier Compliance Canada Inc. doing business as Outlier Compliance Group, a consultancy specializing in compliance solutions for reporting entities ranging from banks to dealers in virtual currencies (like bitcoin) to real estate firms, is one of the first to offer compliance services in the metaverse. Outlier will be joining as one of the professional service providers setting up shop in conjunction with Grinhaus Law Firm, a leading Canadian law firm in Blockchain regulatory advisory, and DGM Financial Group, a prominent Trust and corporate services office which helps structure crypto businesses internationally, in Decentraland, to service clients globally and through the metaverse.

Fraud & Reasonable Grounds to Suspect

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on January 10, 2022

One of the themes that was prevalent in Canadian AML for 2021 was the relatively low bar represented by “reasonable grounds to suspect” (RGS) and the types of transactions for which FINTRAC expected suspicious transaction reports (STRs) to be filed. One of our astute colleagues worked with us to craft some specific scenarios (the full version, including FINTRAC’s response, can be viewed here), and FINTRAC’s response seems to confirm a significant shift in position from previous discussions. Specifically, STRs are expected in cases of fraud, including cases in which the reporting entity’s client is believed to be the victim of fraud.

Proliferation Financing

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on January 4, 2022

What is it, and why should AML compliance professionals be paying attention?

If you’ve looked at the Financial Action Task Force (FATF)’s recommendations recently, you’ve no doubt noticed that there are now three big topics on the covering page:

888 – Reflecting 8 Great Years!

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on December 31, 2021

On August 8^th (the 8^th day of the 8^th month) this year, Outlier Compliance Group turned 8 years old. It seems like a good time to stop and reflect on the company’s journey to this point, and where we’re going next…

Don’t Share STRs or STR Data

Amber D. Scott, Co-Founder, Chairperson & Strategic Advisor on February 3, 2021

Recently the Compliance Officer from a small reporting entity reached out to me to ask an uncomfortable question: should they provide copies of the Suspicious Transaction Reports (STRs) that they had filed with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) to their financial services providers such as a credit union or bank?

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