On August 16, the Canadian Investment Regulatory Organization (CIRO) released updated guidance relating to anti-money laundering in GN-3200-23-001 (Guidance Note). The updates to the previous guidance reflect changes in Canada’s anti-money laundering and anti-terrorist financing laws since the guidance was last updated in 2019, as well as additional guidance available from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Updates in the Guidance Note also reflect the interim rules, CIRO’s name and to clarify that the guidance applies to investment dealers (and not mutual fund dealers) only at this time. The Guidance Note specifically indicates however that CIRO is working on consolidating the IDPC’s and Mutual Fund Dealer Rule’s client due diligence, KYC and surveillance requirements, and developing consistent AML examinations for all CIRO Dealer Members, such that the Guidance Note will be revisited and likely amended again in future.

August 31, 2023