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Anti-Money Laundering

With expanded regulatory powers and an ever-changing regulatory landscape, compliance procedures and obligations for financial services institutions are more prevalent than ever.

The Blakes Financial Services Regulatory group has extensive experience advising all entities subject to Canadian anti-money laundering (AML), anti-terrorist financing and economic sanctions legislation applicable to financial transactions. We advise clients on the current regulatory framework, as well as on any draft legislation and regulatory proposals that may affect them. We act for financial institutions, domestic and foreign money services businesses, foreign exchange businesses, casinos, securities dealers, real estate brokerages and developers, dealers in virtual currencies, accounting firms, merchant acquirers, prepaid card issuers, payment processors, those involved in the jewelry business, among others.

We advise clients on:

  • Compliance with the requirements of the Proceeds of Crime (Money Laundering), Terrorist Financing Act, Guideline B-8 issued by the Office of the Superintendent of Financial Institutions, Rule 1300 and the Anti-Money Laundering Compliance Guideline of the Investment Industry Regulatory Organization of Canada, the Quebec Money-Services Business Act and gaming control legislation

  • Compliance with Canada’s economic sanctions legislation and all underlying regulations, including the United Nations Act, the Special Economic Measures Act, the Freezing Assets of Corrupt Foreign Officials Act, the Justice for Victims of Corrupt Foreign Officials Act  (Sergei Magnitsky Law) and the Criminal Code

  • Reporting requirements under the legislation, including guidance in interpreting the requirement to report "attempted" suspicious transactions

  • Requirements for client identification, know-your-customer, record-keeping, ongoing monitoring reporting and privacy considerations surrounding voluntary reporting

  • The development of product and customer-risk categories and risk assessments

  • Drafting AML compliance programs, including how to prepare for compliance audits and delivering in-house training programs, consistent with legislative and regulatory requirements

  • Registering as money services businesses under the federal and Quebec registration regime

  • Existing AML products and new product initiatives

  • Compliance procedures surrounding unique business lines, including wealth management, private banking and merchant acquiring

  • Compliance opinions on the requirements of the provisions of the legislation

  • Regulatory issues that we discussed and reviewed with regulators on behalf of clients and challenging adverse regulatory findings