Compliance Questionnaire - Money Services Businesses sector

Part A

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Organization's legal name and Head Office address:
Please indicate the type of premises for the above Head Office address: Commercial / Retail, Residential / Dwelling House, or (If other, specify)
Name and title of the individual completing questionnaire:
Contact information:
Business telephone:
Business fax:
E-mail:

A1 - Does your organization have branches operating in Canada?

A2 - If you answered yes to A1, please list the locations of the branches (include address, city, province/territory, etc.). If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A2

A3 - Does your organization have branches outside Canada?

A4 - If you answered yes to question A3, please list the other countries where the branches are located. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A4.

A5 - Does your organization have agents operating in Canada?

A6 - If you answered yes to A5, please list the name(s) and location(s) (include address, city, province/territory, etc.) of the agent(s) operating in Canada. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A6.

A7 - Are you an agent of any other organization?

A8 - If you answered yes to question A7, please list the name(s) of the organization(s) you are an agent for? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A8.

A9 - How many employees are there in your organization?

A10 - For the previous fiscal year, please indicate the approximate annual value of all currency exchange and money services business you conducted. $ ____

A11 - Does your organization provide currency exchange and/or wire transfer services to other Money Services Businesses?

A12 - What is your organization's primary bank / credit union / caisse populaire / trust company?

A13 - What is your organization's secondary bank / credit union / caisse populaire / trust company?

A14 - Is your organization a subsidiary of any other entity subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If so, what is the name and address of the parent organization?

A15 - Does your organization own any other entities that are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If so, what are the name and address of these entities? If there is not enough room here, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A15.

A16 - Please indicate if you are licensed in any of the following sectors. Check all that apply: Life Insurance, Securities, Real Estate, Accounting, None applicable

Part B

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B1 - Have you fully implemented a compliance regime in your organization (which includes the appointment of a compliance officer, development and application of compliance policies and procedures, review of your compliance policies and procedures as necessary and ongoing compliance training)? Refer to FINTRAC's Web site Guideline 4 at http://www.fintrac-canafe.gc.ca/publications/guide/Guide4/4-eng.asp

B2 - If you answered no to question B1, at what stage of implementation is your compliance regime? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer B2.

B3 - Have you appointed a compliance officer to meet your reporting, record keeping and client identification obligations?

B4 - If you answered yes to question B3, please provide the name and telephone number of the compliance officer.

B5 - Does your compliance officer report directly to senior management of the organization? (Senior management could be the owner or chief operating officer of the business, any senior executive or any member of senior management or the board of directors)

B6 - How does your organization keep up with any changes in reporting, record keeping or client identification obligations? (check all that apply): Media (newspaper, television, etc.) , FINTRAC's Web site , Other web sites , Seminars, training or conferences , Other

B7 - Have you consulted the FINTRAC Guidelines?

B8 - If you answered yes to question B7, do you find them useful?

B9 - Do you have any suggestions for improving the guidelines?

Part C

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C1 - Do you have policies and procedures to ensure your reporting, record keeping and client identification requirements are being met?

C2 - Are your policies and procedures in writing?

C3 - Within the last twelve months, has your organization conducted financial transactions with individuals or entities based in any of the countries on the Financial Action Task Force (FATF) List of Non-Cooperative Countries or Territories? For information about this list, please refer to FINTRAC's advisories at http://www.fintrac-canafe.gc.ca/publications/avs/1-eng.asp

C4 - If you answered yes to question C3, which countries were involved and approximately how many transactions were conducted with each country? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer C4.

C5 - Does your organization cross-reference the names of clients with any anti-terrorism lists of names published by the Canadian government? For more information about these, please refer to the List of Names Subject to the Regulations Establishing a List of Entities made under subsection 83.05(1) of the Criminal Code or the United Nations Suppression of Terrorism Regulations provided by the Office of the Superintendent of Financial Institutions at http://www.osfi-bsif.gc.ca

Part D

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D1 - Have you implemented a process for reviewing your organization's compliance policies and procedures to determine their effectiveness?

D2 - Has such a review already been conducted for your organization?

D3 - If you answered yes to question D2, how often is a review conducted? More than once a year, Once a year, Less than once a year

D4 - If you answered yes to question D2, the review was conducted by: (Check all that apply): Compliance officer, Internal Audit, External Audit, Consultant, Other ___

D5 - If you answered yes to question D2, when was the review completed?

D6 - Are the results of the review documented?

Part E

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E1 - Does your company/organization provide training about your reporting, record keeping and client identification obligations?
If you answered yes to question E1, answer question E2.

E2 - Describe how your training is delivered. Include information about the mode and frequency of delivery as well as a general description of who is required to take the training. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer E2.

Mode of training: In a classroom with trainer/Seminar, Self-directed, Computer-based, Other
Frequency of training: Yearly, More often than yearly (e.g., seasonally, quarterly, etc.) , When new staff is hired , In special circumstances, Other
Who receives the training: All Staff, Brokers / Nominees / Managers, Sales Representatives, Other
Type of material: Handouts, Test, Presentation or group discussion, Other