1. © Grant Thornton International Consortium on Governmental Financial Management Jennifer Fiddian-Green Investigative Forensic Accountant Stopping Money Laundering Combating Terrorism: Canadian Legislation and Effort

2. © Grant Thornton Canada: contribution to global effort to combat ML & TF Canada’s intelligence unit (FINTRAC) became operational October 2001 Reporting of suspicious transactions began November 2001 Large cash, wire transfer transaction reporting and compliance regime requirements began in June, November 2002. Customs seizure reports and Cross Border Currency Reports are reported to FINTRAC by the CCRA (Canada Customs and Revenue Agency). All currency >= $10,000 Canadian, imported or exported into/out of the country, must be reported to the CCRA. Previously, Canadian effort was led through police investigative efforts- Integrated Proceeds of Crime Units To date FINTRAC has received over 2.2 million reports and made over 103 disclosures to law enforcement (78 ML and 24 TF)

3. © Grant Thornton Requirements: Canadian Legislation Organizations required to report: –All banks, credit unions, caisses populaires, life insurance (including all brokers & agents) and trust and loan companies; –All persons engaged in the business of dealing in securities; –Foreign exchange dealers, money transmitters, cheque cashers, money vendors –Real estate brokers and agents; –All casinos; –All federal and provincial departments or agents engaged in activities similar to the above; and –Accountants in regards to specific activities. Note: Lawyers are not currently required to comply with Part 1 of Canadian PCMLTFA. Part 1 requires reporting of suspicious and prescribed transactions, as well as ascertaining identity procedures, training, policy and procedure and program review. This is under review.

4. © Grant Thornton Requirements: Canadian Legislation Compliance Regime: Canada’s PCMLTFA requires organizations to implement a compliance regime which includes designation of a compliance officer, documented policy and procedure, regular training for staff and a regular review of the compliance system Reporting requirements include suspicious, terrorist group properties (obligation on staff as individuals to report), large cash transactions and reports of other specific types of transactions depending on industry sector. KYC: requirements to ascertain identity include viewing one piece of original ID (most organizations view two pieces). FINTRAC has provided guidance for what is acceptable ID to view.

5. © Grant Thornton What are the results of your training? Find out what issues your people are dealing with in advance of training- ask them to come prepared with questions. What are they suspicious of? What is unusual? Often these answers are presumed. Needs to be a detailed assessment and understanding process before training can take place. Take the training back to the work space- make sure people really understand they need to take ownership. See attached course completion form.

6. © Grant Thornton Training Course Sample Evaluation Form Objectives What were the most important factors that influenced your decision to take this course? Select all that apply: need it to do future job assignments, identified as a development opportunity by coach, personal interest, other (please explain) Did the facilitator review the objectives of the course at the beginning of the course? Yes/No Were you given the opportunity to have input into the objectives for the session? Yes/No Were the objectives identified at the beginning of the course fulfilled by the end? Yes/No/NA Did the objectives published with the registration material give you an accurate indication of course coverage? Yes/No Did the course coverage include a discussion of responsibility for learning and responsibility for use of learning? Yes/No Do you feel that you will use the concepts/skills covered in this course when you return to the office? Yes/No Will you feel confident using the concept/skills when back in your office? Yes/No/NA Overall Comments: Is it important that we repeat this course? If not why? Please give examples Yes/No Please identify 2 things the facilitator did well Please provide 2 pieces of advice for the facilitator Please rate the value of this course to you: Excellent ….Poor

7. © Grant Thornton Canadian Requirements (vs. United States) Industries impacted includes: –All persons engaged in the business of dealing in securities, Real estate brokers and agents Not included (currently): –travel agents, vehicle, jewellery, and antique dealers Understand the Canadian banking system: –6 large domestic banks dominate the financial sector- close to 90% of the $1.7 trillion banking assets in the country are with these banks. All of these banks are reporting regularly, as well as the credit union system and money services businesses

8. © Grant Thornton Canadian Requirements Reporting of all international wire transfers $10,000 or more (Canadian) (last check approx. $7,500 US)- significant opportunity for FINTRAC to understand and assess movement of funds into and out of the country. Electronic reporting is mandatory- opportunity for timely analysis and disclosure (www.fintrac.gc.ca) Transaction reporting not activity reporting- no requirement to report suspicious activity is transaction is not completed. Voluntary reports can be made.

9. © Grant Thornton Canadian Emerging Challenges Canada has significant opportunity to build intelligence on the movement of funds internationally. Struggle/challenge is ensuring we have the enforcement resources to proactively respond: Egmont Group for international referrals Canadian law enforcement for domestic investigations FINTRAC has now begun phase of risk based compliance reviews Significant organized criminal activity

10. © Grant Thornton Jennifer Fiddian-Green CA  IFA, CAMS, CMA, CFI, CFE Investigative Forensic Accountant Contact Information: 416-360-4957 jfiddian@grantthornton.ca jfiddian@grantthornton.ca