Dept of Finance – Anti-Money Laundering Regime

April 27, 2018

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Dept of Finance – Anti-Money Laundering Regime

Letter Summary:

Canada’s anti money laundering regime is scheduled for review every 5 years (The Proceeds of Crime and Terrorist Financing Act).  The paper reviews the history of Canada’s anti-money laundering and terrorist financing legislation and proposes expanding the scope of the act to include beneficial ownership information, finance and leasing companies, white label ATM companies and politically exposed persons.  

Overview of the Council’s Comments:

The council is supportive of the revisions and framework proposed in the discussion paper.  In the case of beneficial ownership data and the collection of data on politically exposed persons, the council queries whether the existing scope and methods of collection are adequate given today’s rapidly evolving technologies (block chain, crypto currencies, biometric identification etc. etc.).  

The council would support the creation of a robust national registry at the federal level that would include beneficial ownership data on all reporting entities including designated non-financial businesses and sales representatives, real estate developers, casinos, dealers in precious metals and stones and other high value goods.