Independent AML Review

Independent Review

CanadaAML specializes in performing independent reviews of AML programs. Our efficient method is designed to perform the AML review without interrupting your daily operations. We visit your offices to conduct interviews and review certain documents. This takes no more than a day and you do not have to halt your operations during our visit - our review can be performed while you continue to run your business as usual. After our visit to your office, we will document the work performed and write a report that you can share with FINTRAC and your bank.

What to expect?

What is the frequency of AML review?
Depending on the size of your operation, a typical review may entail the following:
  • Interviews with those handling transactions and with their supervisors to determine their knowledge of the legislative requirements and your AML policies and procedures.
  • Review of the criteria and process for identifying and reporting suspicious transactions.
  • Sampling of large cash transactions followed by a review of the reporting of such transactions.
  • Sampling of international electronic funds transfers (if those are reportable by the reporting entity in question) followed by a review of the reporting of such transactions.
  • Test of the validity and reasonableness of any exceptions to large cash transaction reports including the required annual report to FINTRAC (this is applicable only for financial entities who choose the alternative to large cash transactions for certain business clients).
  • Test of the record keeping system for compliance with the legislation.
  • Test of the client identification procedures for compliance with the legislation.
  • Review of the risk assessment.
Although FINTRAC requires the independent review to be performed every two years, certain organizations require this review to be performed on an annual basis. We suggest you contact your risk assessment document and other stakeholders such as your financial institutions to determine the required frequency of independent AML review.

Why an AML review is required?

Per AML regulations, you are required to arrange for a review of your AML compliance program on a biannual basis. This review should not be performed by management that is responsible for day-to-day compliance activities. Areas of review must include:
  • AML Policies and Procedures
  • AML Risk Assessment
  • AML Training Program
This is a mandatory requirement and FINTRAC provides the following guidance:
" Another 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. It has to cover your policies and procedures, your assessment of risks related to money laundering and terrorist financing and your training program to test their effectiveness."

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