The RCMP is making calls to cryptocurrency companies this week. Here's what you need to know.

Happy summer from The AML Shop everyone! We hope that you’re staying cool during this heatwave.

Our team loves connecting with our clients to stay in-the-know with what’s happening in their world and as one of the many ways we remain informed.  This week, our cryptocurrency clients told us they received an email from an RCMP officer requesting contact information about their business.  

If you receive a similar email, don’t panic. This request is not specifically targeted at your business.  

Our team was proactive and contacted the RCMP directly for details. Cpl. Steve Harten shared that he was asked to compile a contact list for each virtual currency business that is currently registered with FINTRAC.  The purpose of the list is for law enforcement to have a point of contact should they need to obtain more information or issue a production order.  

Garry Clement, our Adjunct Advisor who had an esteemed career with the RCMP, including its Integrated Proceeds of Crime program says,  “If you receive an email similar to what we have described, it’s always good to provide the information requested,  as it demonstrates a commitment to compliance and it always pays to have good relations with law enforcement.”

With that being said, The AML Shop confirmed with Cpl. Harten that providing this information is completely voluntary, so you are under no obligation to provide the requested contact details if you don’t feel comfortable doing so. Clement also shares that, “cooperating with law enforcement shows good corporate citizenship which is such an important piece of every business’s fabric these days.” 

Cpl. Harten has provided his contact details. If you would like more information on the virtual currency contact list, or require law enforcement assistance or perspective on an issue relating to virtual currency,  you can contact Cpl. Harten directly, via email at steve.harten@rcmp-grc.gc.

As always, whenever you receive or hear about something you’re unsure of, call your AML support team or colleagues. You are always welcome to call the AML Shop, as it’s usually a good place to start.

Stay cool and watch our website for more news and updates like this.  If you have an idea or question that you’d like us to answer, we’d love to hear it! Email us at: shamela@theamlshop.ca

Why a Director of First Impressions is any company’s first step to building trust. By Matt McGuire

They say that humans need less than two seconds to form a first impression. I’d imagine that’s even less nowadays when our minds are bombarded for competing attention and headspace. 

If people are going to form their own opinion and perspective without much information and, in such an unreasonable time frame, why would a company dedicate resources to a position titled, Director of First Impressions? 

Here at The AML Shop, let us start by telling you about Shamela Styles. Shamela is the first person that our clients, potential clients, partners, media and you, may connect with when you contact us in whichever channel you choose. We believe that fundamentally, humans enjoy other humans. If our current world situation hasn’t heightened our need for connectivity, it certainly has made us all more aware that we are pretty similar and just want what’s best for ourselves, our families, our community and our earth. So how does a simple job title share a story with grand beliefs and hopes for the greater good? 

Because a Director of First Impressions boils down to one elusive value that companies spend millions of dollars on each year trying to attain: trust. When you speak or work with Shamela, you can tell, in under two seconds, that you’re speaking with a highly competent professional who is both chameleon and unicorn. She can adapt to any situation, be tasked with something completely out of her wheelhouse, and knock it out of the park.  She has a heart so magnetic, you’ll find yourself looking for reasons to continue building trust and a relationship with her and by extension, our entire company. 

Trust is built over time, of course, but you never get a second chance to make a good first impression, so they used to say. 

Shamela is our brand champion. Knowing our business from the outside-in, understanding our clients’ and industry’s unique nuances, as well as the very complex systems of AML regulations. She welcomes every chance to make a first impression in all aspects of her role. People notice this. People feel her kindness and loyalty to her work and in turn, to them. 

A Director of First Impressions is front and centre. Companies who survive now need to make bold moves and shift the way they align their most valuable people into the roles they were born to play. The AML Shop is built on a passion for excellence and expertise in every aspect of our work. Creative, meaningful roles that still have a long list of duties and responsibilities, are moving beyond the typical templated HR turn and burn mentality. People will always remember that first call, first message or first meeting where it felt like someone was waiting for your arrival and made you feel so special, you let down your guard, forgot about any agenda and realized, this place is different. They are listening to me. She is listening to me. She remembered my travel nightmare last trip and asked if the airline found my son’s note that he slipped into my purse. I can trust this place, this person whom I’ve never met until today, yet feels like we’ll become fast friends because I can trust what she is saying. I believe what she says because I see what she does.

And all of this from our fabulous, irreplaceable Shamela, who is empowered with everything at her disposal that lets her know she is valued, she is essential and she is a trusted lead on our team. 

Don’t you wish everyone you had to call or email today was a Director of First Impressions? I guarantee your attitude, outlook and the overall day would be met with enough warmth and confidence to ask Shamela, where do I sign?

Remote work is not a barrier to a great review. Clients report it's the perfect time to evaluate your AML program and retool while client-facing activities have abated.

FINTRAC’s statements about AML during Covid stress that the compliance show must go on… and with good reason. Criminals are clearly taking advantage of perceived vulnerability to perpetrate pandamic-related fraud and related money laundering. STRs are first priority, towards FINTRAC’s unrelenting focus on compliance for intelligence. 

While FINTRAC exams are currently suspended, FINTRAC’s expectations for compliance effectiveness reviews have not changed. A well planned and executed review not only prevents surprises for future examinations, but it also assists in preparation for known changes to legislation and guidance.

Remote work is not a barrier to a great review – and it might be the perfect time for you to evaluate your AML program and retool while client-facing activities have abated.

 The AML Shop is well-practiced at conducting its procedures for a review from a distance – in much the same manner as FINTRAC conducts its desk reviews. We apply our insights from participation in dozens of FINTRAC examinations, from their guidance and examination manual, from the practices of your peers, and from international standards. Following their lead, our procedures are focused on risk and ongoing monitoring, with detailed and deep analytics for high-risk clients and transactions to test effectiveness.

 In almost all instances, our review begins with an in-depth interview with the Chief Anti-Money Laundering Officer and a detailed information request. We exchange documents using secure services with Canadian-only storage with guaranteed privacy. Records-review can be conducted with read-only auditor access to the back-office and transaction monitoring, or through extracts. And our interviews can be planned around the schedules of your team, service providers, and agents.

 Most reviews can be conducted in four to six weeks. We have many clients taking advantage of this unique time we find ourselves in. There’s still plenty to do to remain fully compliant yet many businesses don’t have the resources to conduct these reviews themselves. We’re your AML partners every step of the way. Starting with a compliance effectiveness review is a great way to meet you and your team and learn about your business while ensuring you are fully compliant. Contact Matt McGuire at matt@theamlshop.ca.

The AML Shop’s outsourcing services are a lifeline to clients that are challenged by the expectation that it’s ‘business as usual’

The AML Shop’s outsourcing practice is alleviating the worries and workload of AML professionals in light of FINTRAC’s announcement that there is no excuse for not meeting compliance regulations during COVID-19. They’ve made it clear that it’s business as usual. We say it’s anything but. 

Some outsourced clients have already reached out for additional support because they are either short-staffed or find themselves needing a hand in meeting their AML compliance duties. The AML Shop realized that there could be more businesses out there needing this exact type of help.

Coupled with the news that The AML Shop is seeing a massive increase in COVID-19 related fraud, it has created the perfect storm of a major workload increase and not enough staff or expertise to get it all done.  

It’s unfortunate that people are profiting through crime during a time of such uncertainty, while taking advantage of people’s vulnerabilities and trust. Fraudsters sense that the spotlight is shining on other issues so as the saying goes, while the cat’s away the mice will play.

Matt McGuire recently participated in a podcast series called Captivated Audience, which is so timely and enlightening on how COVID-19 is affecting AML businesses in Canada. You can listen to the 13-minute recording by clicking the link here.  

Matt shares his ideas on FINTRAC’s recent position and offers great tips on how to think beyond today in terms of what financial crime professionals should be planning for when this settles down. Here’s a hint: plan on asking for a bigger budget and overhaul your own compliance programs so you are ultra-prepared next time or as COVID-19 continues to affect our business for years, as some are predicting.

He also suggests ways to have staff optimizing their time working from home such as online classes. And a big silver lining: some people are saving anywhere from two to five hours per day in commuting time which offers a better life balance and maximizes work output in a more efficient way. ​You will love this candid, funny and valuable podcast! 

Matt says, “We only want the very best for our clients and their colleagues. Know that we are ready to help you with our established outsourced practice dedicated to remotely supporting compliance teams”. The AML Shop provides outsourced support to companies across the country including credit unions, money service businesses and payments service providers,  securities dealers and fintechs. If you find yourself treading in deep waters, or want to have a backup plan, (or business continuity plan), in place should things change in your organization, we’re happy to help.

Reach out and we’ll work together to meet your specific and likely, changing needs in a time where little is certain. Please email: info@theamlshop.ca or call us at 1-877-701-0555.

About The AML Shop​ 

Our team of veteran compliance advisors share our goals to help clients manage their risks, maximize their opportunities and achieve and maintain compliance. We provide: expert advice; support with regulatory exams; development and reviews of financial crime compliance and risk management programs; assistance with the validation of AML technology; and the management or staffing of your compliance functions and compliance teams. We serve clients across Canada in every regulated sector and in emerging industries with a specialty in FinTech and Cryptocurrency.  

 

Update to this week's FINTRAC announcement around reporting requirements

Further to their initial announcement earlier this week, in light of COVID-19 FINTRAC still expects reporting entities to meet all of their obligations, including in relation to reporting. On the bright side, FINTRAC states that for the time being, they will not be contacting reporting entities to initiate new examinations.

If your team needs help with meeting these requirements, we are here to help. We are working with clients on a temporary basis as we navigate the uncharted waters of COVID-19. We can become an extension of your team, providing the extra resources needed to continue business continuity especially for reporting and all things AML compliance-related.

Please contact us via email or telephone if you’d like to discuss ways to work together: matt@theamlshop.ca or 1-877-701-0555 ext. 101.

Message to all reporting entities in light of COVID-19 from the Department of Financial Transactions and Reports Analysis of Canada

Due to the recent outbreak of COVID-19, FINTRAC understands that businesses (i.e., reporting entities), subject to obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations, may face challenges in meeting their obligations in situations where staff may be reduced or unavailable to do their regular work.

We expect that reporting entities will do everything possible to meet all of their obligations, including in relation to reporting. However, we understand that some reporting entities may find themselves in a situation where they are unable to meet some of their obligations. In such a case, FINTRAC is asking that reporting entities document the reasons why and keep a record of it. Given the situation, FINTRAC will take a reasonable approach with its compliance activities.

When it comes to reporting, priority should be given to submitting suspicious transaction reports (STRs). In a situation where reporting entities may be in possession of critical information related to national security matters that should be normally submitted to FINTRAC but, for some reason, cannot be provided in a timely manner, we would ask that you send an email to emergencyreport-declarationurgente@fintrac-canafe.gc.ca, and someone will then contact you. A written report should follow as soon as possible.

Given the current high level of calls related to COVID-19 on the Government of Canada telephone lines, FINTRAC will no longer be offering telephone support for inquiries about the following: compliance obligations, reporting system access issues, and MSB registration obligations. For these matters or any other urgent inquiries, please contact your regional compliance officer or send an email to guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

For technical assistance, please contact FINTRAC’s Tech Support team at the following email:

 tech@fintrac-canafe.gc.ca.

Note that depending on the volume of requests, you may experience a slower level of response.

Date Modified: 2020-03-19

Department of Finance and BOC's Proposed Legislation for PSPs: We Can Help

Recently, the Department of Finance and the Bank of Canada (BOC) presented details on proposed legislation related to retail payment service providers (PSPs). Key areas of this legislation include; operational risk, financial risk, market conduct risk, efficiency risk, money laundering and terrorist financing risk.  While we don’t know the timing of its release, once legislation is passed, there will be guidelines to support it. 

We can share a few things with you at this time. You will find below some of the highlights that we feel will have the biggest impact. If you’d like to review the DOF’s 2017 consultation paper , click and enjoy reading the full recommendations.

If you or your team have any questions about this, please connect with us. We work with PSPs regularly to ensure they meet all AML compliance regulations whether they are just starting their AML program or need The AML Shop’s expertise to refine certain areas. We’d love to hear from you.

Here are some of the key highlights that we thought were important to share:

  1. The legislation will be based on functions; Finance was pretty clear that these were still proposed and not finalized: provision and maintenance of a payment account, payment initiation, authorization and transmission, holding of funds and clearing and settlement.

  2. There are four principles that have been identified to guide the development of the oversight framework should be proportionate with the level of risk posed by a payment activity; oversight measures should not create a barrier to competition and innovation by unduly burdening PSPs.

    • There should be consistency of oversight, irrespective of the type of entity or the technology.

    • Oversight should be designed to maximize effectiveness with clear, accessible and easy to integrate requirements within different payment services.

    • If an entity is already under prudential oversight, there may be some exemptions under this new legislation.

    If an entity is already under prudential oversight, there may be some exemptions under this new legislation.

 The BOC will be the primary regulator of this legislation, once final, and will have three components to their mandate:

  1. Registration: all PSPs will be required to register with the BOC.  The registry will be public and the registration process has not been established yet.

  2. Operational Risk Management: this will be a principles-based approach similar to that of larger systematically important systems (like Payments Canada). 

  3. PSPs will be required to provide reporting to the BOC on their operational risk management programs.  


The BOC will provide guidance to PSPs on end-user funds safeguarding.  PSPs will be required to report certain activities to the BOC based on the guidance. The BOC will have oversight responsibilities and may even perform examinations of the PSPs.  Not all PSPs will be looked at equally; it will be a risk-based approach.

The BOC will also provide time for all PSPs to adjust to the new expectations, although there was no specific mention of how much time or any deadlines.


IIROC's Updated Guidelines Will Improve How to Attain a Reasonable Belief of Identity

IIROC has now published an update to their AML Guidance with an effective date of June 1st, 2020 to be in place. This is great news, as it will remove the need to collect clients’ citizenship, occupation and employment information and reduce the burden from collecting identification to attaining a “reasonable belief of identity” of these persons. For all the details, click here for the notice link from IIROC.


OSC Makes It Easier for Smaller Investment Firms to Outsource Compliance Role

The AML Shop is a one-stop-shop for AML compliance needs, serving clients all over North America. The feedback we often hear from smaller investment firms is that they aren’t ready to hire a full-time compliance officer, however it is a regulation that they must follow. That is, until this week’s announcement from the Ontario Securities Commission.

The OSC has removed such barriers, enabling smaller investment firms to choose to outsource its compliance role.  This is good news for smaller firms that can improve resources and efficiencies in an outsourced partnership.

Here is a link to the full article. And if you’d like to discuss your outsourcing needs, get in touch with us by emailing info@theamlshop.ca.


The AML Shop’s Clients and Colleagues Win Big

We are so thrilled to share the news that our clients, Paybright and nanopay, won top honors at the Canadian FinTec and AI awards last week. Our friend, Matthew Burgoyne, Partner at McLeod Law LLP, received a nomination for Law Firm of the Year - congratulations to this amazing team!

The cherry on top is that our valued colleague, Meridian, was the recipient of Central 1’s Credit Union of the Year Award. Take a bow everyone! We know how hard you all work to make this kind of magic happen and we are so proud of you!


Watch the AML Shop Invitational Conference

If you missed our inaugural AML Shop Invitational Conference on April 11th, you can enjoy all of the content and speakers that our 100 guests experienced.

We are pleased to offer a video recording of the full conference for a small investment of $230.

Here’s what you need to know to download your all access pass to the conference:

● Follow this link where you will be asked to register
● You’ll be directed to a payment page where you can pay by credit card, VISA Debit Card or PayPal
● Enjoy the line up of outstanding experts and excellent Q&A

Here is our list of speakers from the conference that you will see during the recording, click here

CONFERENCE PHOTOS

Have a look at our gallery of photos from the 2019 Conference, click here

QUESTIONS / CONTACT

If you have any questions about this recording or have any ideas for the 2020 Invitational Conference,
please contact our Office Administrator, Shamela at Shamela@theamlshop.ca

The AML Shop staff gain prestigious Certified Cryptocurrency Investigator designation

Matt McGuire, Co-Founder of The AML Shop, is the first on his team to become certified in cryptocurrency investigation through the Blockchain Intelligence Group of Vancouver. This designation adds another layer of expertise to The AML Shop’s service offering and furthers its commitment to continuous education. Other AML Shop leaders will take the exam in the coming months, leading to more designations.  

The certified cryptocurrency designation provides additional knowledge and awareness of the compliance regulations surrounding cryptocurrency and builds the skills and qualifications of The AML Shop’s team of experts.

Matt shares that, “cryptocurrency is evolving at a fast pace and we want to have the very best knowledge of this space. Our team helps our clients, including banks, to determine where cryptocurrency wealth originates from, as well as monitoring and mitigating risk for crypto tokens and exchanges. We also provide services in forensic tracing when we are asked to assist in the course of civil or criminal proceedings”.

The Cryptocurrency Investigator Certification Course was created by Blockchain Intelligence Group to help law enforcement, the financial sector and regulators learn how to bring security and accountability to cryptocurrency.

For more information please contact Matt McGuire.


The AML Shop joins list of signatories to Federal Finance Minister on Beneficial Ownership

We are pleased to be a part of Transparency International’s list of signatories in an open letter to Federal Finance Minister Bill Morneau, encouraging the federal government to advocate for a publicly accessible pan-Canadian company registry of beneficial owners in upcoming conversations with provinces and territories, and to outline a consultation timetable to explore all registry options (including a publicly accessible registry) in Budget 2019.

Block Equity is acquired by Coinsquare and thanks The AML Shop for setting it up for compliance success.

FOR IMMEDIATE RELEASE - December 10, 2018

Toronto, ON - Block Equity is acquired by Coinsquare and thanks The AML Shop for setting it up for compliance success.

Canadian Crypto Exchange company Coinsquare recently acquired Block Equity Inc., (BlockEQ), for $12M. BlockEQ has been a client of The AML Shop since its inception and worked with their team of experts on setting up its operation, especially its regulatory compliance.

Jon Lister, Co-Founder and President of BlockEQ says, “We are really pleased with this growth opportunity. Coinsquare is one of the reasons we got into this space, so to work with them and their team is very exciting."

BlockEQ started about one year ago and partnered with The AML Shop from the start. Lister shares, “We knew that one of the major keys to our success would be ensuring the highest standards and procedures in our compliance and regulatory requirements. The AML Shop set us up for this success from the beginning and brought such a high level of expertise that resulted in our company becoming desirable to others. We believe it is important to build a business the right way from the beginning. In order to build a lasting financial institution you need to structure your operations with compliance in mind, as new regulations come into effect.”

Lister further says that “It was great working with The AML Shop and its team members. They are responsive, efficient, and supportive and we are very thankful to them for positioning us so strongly for this opportunity.  They took the time to understand our business model and were able to craft our policies and procedures that were specific to our business”.

For more information on the acquisition please click here:

https://www.ccn.com/canadian-crypto-exchange-coinsquare-acquires-stellar-wallet-blockeq/

About The AML Shop

Our team of veteran compliance executives empowers businesses with the most practical, informed and strategic regulatory support services. Our goals are to help our clients manage their risks, maximize their opportunities and achieve and maintain compliance. We provide: expert advice; support with regulatory exams; development and reviews of financial crime compliance and risk management programs; assistance with the selection, enhancement and validation of technology; and the management of your compliance functions or staffing of your compliance teams.

With offices in Toronto and Ottawa, we serve clients across Canada in every regulated sector, and in emerging industries. To learn more about the AML experts at your service, please visit The AML Shop.com

For more details on this story please contact Matt McGuire.


The AML Shop Acquires Clement Advisory Group

We are pleased to share that The AML Shop has acquired the regulatory compliance advisory practice of Clement Advisory Group  (CAG), a licensed private investigative agency led by former RCMP Superintendent and Cobourg Chief of Police, Garry Clement. CAG has been providing regulatory advice and investigative services since 2009

Matt McGuire, Founder of the AML Shop says, “This is a great day for both CAG and The AML Shop. Having worked together for a number of years and knowing that Garry has built such a respected and successful business, it made sense for us to carry on his legacy. We are thrilled that Garry will remain a senior advisor to us and we will continue to collaborate to bring the very best in service to clients.”

Garry Clement, President of CAG shares, “I could not have found a better company to acquire the responsibility for the many clients that have been integral to CAG’s success since 2009. I trust in the ethics and knowledge of Matt and his highly trained team of AML experts.  Due to the complexities that organizations face today, in order to achieve AML and CTF requirements, it is essential that the financial sector relies on companies that have a team of subject matter experts. I know this to be the case with The AML Shop and am pleased to remain in a senior advisor role.”

As part of the acquisition, The AML Shop will gain access to CAG’s program models, training materials and evaluation methodologies, and will be continuing the distribution of Garry’s widely read newsletter in the coming months.

The acquisition takes effect on October 1, 2018. Any current clients of either company or anyone who would like further information is encouraged to contact Matt McGuire directly.

Amending Regulations Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act

The proposed Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act 2018 have been published in Part I of the Canada Gazette.

The proposed amendments include changes to the:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Regulations;
  • Proceeds of Crime (Money Laundering) Terrorist Financing Regulations;
  • The Cross-Border Currency and Monetary Instruments Reporting Regulations;
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations; and
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Partnership Announcement - The AML Shop and BIG Blockchain Intelligence Group

Vancouver, British Columbia--(Newsfile Corp. - May 30, 2018) -BIG Blockchain Intelligence Group Inc. (CSE: BIGG) (WKN: A2JSKG) (OTC Pink: BBKCF) ("BIG" or "the Company"), a leading developer of Blockchain technology search, risk-scoring and data analytics solutions, announces that the Company has signed a Partnership Agreement with the AML Shop to jointly deliver customized cryptocurrency forensic services and for the AML Shop to act as a distributor of BIG's proprietary Blockchain investigative platform, QLUETM.