Support for the Consultation

PMAC is supportive of Finance’s focus on reviewing Canada’s AML laws to ensure that they remain responsive to emerging risks and evolving international standards, including the Financial Action Task Force’s (FATF) standards as well as the findings and the recommendations made in the final report by the Cullen commission (the Cullen Report). PMAC believes that meeting the FATF standards improves Canada’s international reputation and improves the global AML framework. We also support the Consultation’s stated goal of creating regulatory efficiencies to facilitate smoother international operation by Canadian companies and ease of compliance.

We do not have any specific comments on the aspects of the Consultation that pertain to issues such as bringing armoured car companies and mortgage lending entities into scope of the PCMLTFA, additional diligence in respect of the money services business registration framework, increasing the fines for crossborder currency reporting penalties to be more proportionate and dissuasive, and appropriate management of correspondent banking relationships. PMAC is supportive of the regulatory burden reducing measures to modernize the service of administrative monetary penalties (AMPs) documentation to reporting entities through allowing for the electronic delivery of such documents.

PMAC applauds Finance for endeavouring to keep the AML regime effective, and able to bring new sectors into scope where there is risk. We believe that maintaining a clear focus on any changes to the AML regime striking a balance between regulatory burden and adopting an appropriate risk-based approach is critical.

Subject to confirmation of our comments below on how this formula will impact securities dealers, PMAC believes that the cost recovery scheme proposed in the Consultation is an appropriate and proportionate approach to recovering FINTRAC’s compliance-related costs.

Click here to view the full submission.