AUM Law would like to remind our clients about their ongoing anti-money laundering (AML) risk assessment obligations. Specifically, the following two risk assessment functions are considered by the Financial Transactions and Reports Analysis Center of Canada (FINTRAC) to be fundamental to a registrant’s AML program:
Performance of an independent review of their AML program every two years.
Documentation of an annual internal risk assessment. Please note that in light of FINTRAC’s recent Risk-Based Approach Guidelines released in April 2016 and other related guidance, this annual internal risk assessment requires a more robust approach as compared to past years.