Developing a Defensible Compliance Program: Best Practices for Navigating Grey Areas Under the PCMLTFR and FINTRAC’s Flexible Measures

May 4, 2021 2:45pm

Stephanie Irvine
Manager, Canada AML and ABC Compliance
Canada Life Assurance Company

Jacqueline Shinfield
Blake, Cassels & Graydon LLP

FINTRAC is expected to release more than sixty new and updated pieces of guidance this year. This practical session will provide insights on how to interpret and operationalize newly released guidance while also exploring how to minimize compliance missteps under FINTRAC’s flexible measures during the pandemic.

  • AML’s evolving regulatory landscape: ministerial directives, regulatory and guidance updates, and published policy positions
  • How to navigate FINTRAC’s flexible measures
  • Interpreting regulatory grey areas
    • Defining ‘reasonable measures’ under recording-keeping requirements
    • Best practices for compliance with ‘soon as practicable’ reporting requirements
  • Impact of new beneficiary requirements on life insurance business and FINTRAC’s expanding scope beyond death claims
  • Interpretating and applying the “loans to public” provision; operationalizing the differences between life insurance and financial entity requirements in respect of these loan products
  • How to leverage existing business processes to address the amended suspicious transaction reporting requirements and support ongoing monitoring of low-risk clients