July 27, 2020 Desk examination resumption

This update to our examination procedures comes into effect on July 27, 2020, and replaces the approach that was in effect as of April 23, 2020.

As indicated on April 23, 2020, FINTRAC understands that due to the ongoing COVID-19 pandemic, reporting entities may still face challenges in fully meeting some of their obligations. In light of this reality, FINTRAC has been reprioritizing its supervisory work, including temporarily deferring desk and onsite examinations over the last few months.

In the coming weeks, as provinces continue to reopen various sectors in the economy, FINTRAC will engage with a number entities in order to resume conducting desk examinations. FINTRAC will not conduct onsite examinations at this time. The Centre will only do so when further restrictions are lifted and when additional guidance is issued by public health authorities.

The purpose of FINTRAC’s examination is to assess your business’s compliance program and its effectiveness, your compliance controls, and your adherence to your obligations outlined in the Proceeds of Crime, Money Laundering and Terrorist Financing Act (PCMLTFA) and associated regulations.

As we start to schedule desk examinations, we will continue to be flexible and reasonable by providing additional time where required to prepare necessary documentation and respond to our requests.

As stated previously, we will consider the impact and challenges caused by the COVID-19 pandemic when assessing compliance with the obligations identified in the PCMLTFA and its associated regulations. This will include being flexible and reasonable in assessing the ability of a reporting entity to update policies and procedures; in adhering with interim COVID-19 related measures; and in effectively fulfilling certain time-bound obligations such as undertaking the two-year effectiveness review.

In cases where there is an impact on your ability to meet a given obligation, you should keep a record indicating why this is the case (for example, a memo outlining reduced staffing levels) and, where possible, include any measures taken to mitigate the risk of non-compliance.

Additional links on FINTRAC examinations:

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