Policy and Procedures Manual
An effective compliance regime includes policies and procedures and shows your commitment to prevent, detect and address non-compliance. The Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) mandates that an anti-money laundering compliance program has to include written policies and procedures to assess the risks related to money laundering and terrorist financing in the course of a firm’s activities.
The level of detail of these policies and procedures depends on your needs and the complexity of your business. It will also depend on your risk of exposure to money laundering or terrorist financing. RMS will evaluate the needs of your firm and tailor the manual to suit your firm’s activities.
Ongoing Compliance Training
If you have employees, agents or other individuals authorized to act on your behalf, FINTRAC mandates that your compliance regime has to include training. This is to make sure that all those who have contact with clients, who see client transaction activity, who handle cash or funds in any way or who are responsible for implementing or overseeing the compliance regime understand the reporting, client identification and record keeping requirements. This includes those at the “front line” as well as senior management.
RMS can provide ongoing training for your staff. Our program focuses on topics such as:
- Requirements and related liabilities
- Policies and procedures
- Background information on money laundering and terrorist financing
Compliance Policies and Procedures Review
FINTRAC mandates that a component of a comprehensive compliance regime is a review of your compliance policies and procedures to test their effectiveness. The review has to be done every two years.
The RMS review will cover your policies and procedures, your assessment of risks related to money laundering and terrorist financing and your training program to test their effectiveness.
RMS will review how a firm assesses risks related to money laundering and terrorist financing including risk assessment, risk‑mitigation and ongoing monitoring.
Per FINTRAC, a risk assessment is an analysis of potential threats and vulnerabilities to money laundering and terrorist financing to which your business is exposed. The complexity of the assessment depends on the size and risk factors of your business.
In performing your risk assessment, RMS will evaluate common and industry-specific indicators related to your products and services as well as to occupation, business, financial history and past transaction patterns of your clients. Upon completion, RMS will provide a detailed report outlining risk ratings assigned to various tasks and services applicable to your firm.