The Canadian Securities Administrators (CSA) issued a staff notice on April 16 relating to the reporting requirements of registrants, exempt international dealers and exempt international advisers with respect to terrorist financing. The notice is intended to provide information on the new consolidated reporting form and the submission of monthly reports.
It is important to note that while there is some legal uncertainty as to the applicability of such reporting requirements to exempt international dealers and exempt international advisers, by issuing the staff notice the CSA is clearly stating the CSA view that exempt international firms should be submitting the monthly reports.
For firms that are required to file, there is now one consolidated form, whereas previously reporting requirements of federal laws relating to terrorist financing and those relating to United Nations sanctions were in two separate reporting forms. The reporting process has changed to allow the consolidated form to be submitted by email to a firm's principal regulator. IIROC members, however, are requested to use the forms issued by, and file those forms with, IIROC.