Complying with Bill C-31
As finalized on February 11, 2014 (with Royal Assent on June 19, 2014), Canadian Bill C-31 — which amends the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) — greatly expands the reach and reporting requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). It extends the types of registered organizations to include online casinos, foreign money services businesses (FMSBs), and virtual currency (Bitcoin) dealers.
Bill C-31 also requires all reporting entities to determine if they are doing business with individuals who may be identified as “politically exposed persons” (PEPs). Though the definition of PEPs is extremely broad (and the subject of much controversy), it now includes both foreign and domestic PEPs, as well as heads of international organizations. Not only must the PEPs themselves receive extra scrutiny (enhanced due diligence), but so too must their “prescribed family members” and any other close associates – personal or business .
Because PEP databases contain hundreds of thousands of entries, this requirement could represent a substantial burden for many organizations — especially those with large customer lists or who process a high volume of transactions in a given day.
Accurate, Easy to Implement PEFP Compliance
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