CHOOSING OUR CLIENTS
We are in the business of assessing, preventing and mitigating risks of all kinds. We have a responsibility to our stakeholders to demonstrate how we take reasonable measures to evaluate and analyse a client’s risk level and reputation before entering into any working relationship.
We further ensure that a similar process is in place when selecting the businesses, partners, clients and suppliers it may work with.
We are one of the largest anti-money laundering professional groups in Canada, and receive referrals and client inquiries from any number of sources.
Sometimes clients come to us with mature programs that they’re tweaking to make more efficient, and sometimes they are starting new and unique businesses in emerging sectors. No matter the type of business, we strive to deal with clients who are committed to complying with relevant and prevailing legislation. And we endeavor to know who we’re dealing with, by:
1. Getting to know their business and background
2. Screening them against watch-lists and pay-for-use news services
3. Identifying the individuals in higher risk situations.
Like any professional with deep knowledge of the financial system, such as accountants and lawyers, there are those who will try to exploit our knowledge for nefarious purposes. We have measures and indicators in place to try to weed them out, but may not always be successful.
For clients with discreet engagements, we conduct screening at the outset, and try to make contact periodically, to see how their business and compliance programs are maturing. However, we cannot be responsible for how they operate after we take all care to get them set-up with a rigorous program, and a hand-off so that they understand how to keep the program’s integrity intact.
As with any third-party agreement or working relationship, there can remain some level of unforeseen risk to our company. Should a client fail to meet its obligations and responsibilities around complying with relevant and prevailing legislation of any kind occur, or reputational damage, or misrepresentation of their relationship with The AML Shop, we have procedures in place to respond to and manage such occurrences.
While we remain diligent in monitoring our relationships and how the TAS’s brand is used (with or without our consent), some may misuse our name or the names of our team members to leverage their strength. If you become aware of such a suspected incident, or wish to confirm our affiliation with a particular person or entity, please reach out to us.
One of our primary services involves conducting anti-money laundering, counter-terrorist financing and sanctions compliance effectiveness reviews (CER). The purpose of those reviews is to assess the effectiveness of an entity’s program to comply with the prevailing and applicable legislation, and are designed for the use of the management of those entities. They may be intended for other purposes. Neither the legislation nor FINTRAC’s guidelines require the conduct of assurance procedures, and reviews do not constitute an audit. Our processes generally involve comparing the design of the compliance program to our understanding of the requirements of the applicable legislation, and then looking at records created in the course of operations, on a sample basis to assess if they conform to the standards set out in the compliance program. We are largely reliant on information provided to us to perform that work. Our role is not to express a conclusion, but to point out apparent compliance program gaps and inconsistencies in the application of the compliance program based on records supplied. Our procedures are not designed to find money laundering or terrorist financing, nor to be able to express conclusions about whether or not it has or will occur in the future.
Final versions of those reports are always digitally signed and logged with unique reference numbers. If you have a question about the authenticity of a report bearing our name, please reach out to us for confirmation.
ADDITIONAL POLICIES: