Proposed Changes to Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime

A consultation paper titled Reviewing Canada’s Anti-Money Laundering and Anti-Terrorist Financing regime (Paper) was released in February, which could potentially have broad implications for Canada’s anti-money laundering and anti-terrorist financing (AML/ATF) regime. The Paper is driven by a number of factors, including the requirement in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) that the administration and operation of the PCMLTFA be reviewed every five years, the Financial Action Task Force’s review of Canada’s AML/ATF regime published in 2016, and the Assessment of Inherent Risks of Money Laundering and Terrorist Financing published in 2015.

The proposals contained in the Paper are diverse and far reaching. Some would extend the reach of Canada’s AML/ATF regime. Others would reduce the burden of this regime on reporting entities.  Some of the more noteworthy proposals are:

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