As all registrants know, reporting entities including advisers and dealers are required to report suspicious transactions for money laundering or terrorist financing to the Financial Transactions and Reports Centre of Canada (FINTRAC). As of August 19, 2024, suspicious transaction reports will also be required if there are reasonable grounds to believe that a transaction is related to sanctions evasion. FINTRAC has said that all information that helps identify the transaction as suspected sanctions evasion activity should be included in the report, including information on the products or services involved. Reports should also include information on the ownership, control, and structure of entities involved in transactions, as well as information about related persons or entities involved, and all available identifying information and descriptions of any legal entities or arrangements involved or associated with the financial transactions. FINTRAC released a special bulletin with additional information in June, and registrants (or other reporting entities) should consider amending their policies and procedures to incorporate these new requirements. Additional information can also be found in BLG’s article linked in our July 2024 bulletin.
July 31, 2024