The Convergence of Sanctions & AML
Canada’s Special Bulletin Highlights Confluence
📅 July 24, 2024
📅 July 24, 2024
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in June 2024 released a special bulletin focusing on financial activity associated with suspected sanctions evasion. The bulletin provides critical insights into sanctions evasion methodologies and highlights indicators of suspected sanctions evasion to help Canadian financial institutions and other reporting entities meet expanded obligations under Canadian law and mitigate sanctions evasion, money laundering, terrorist financing, and other financial crimes.
The convergence of sanctions and AML has significantly accelerated since Russia invaded Ukraine in February 2022. FINTRAC noted in 2022 that Russia-based individuals and entities sanctioned by Canada—particularly those whose financial assets have been acquired through corruption and other illegal activity—are likely to deploy established money laundering methodologies to evade sanctions. Sanctions compliance and AML teams should collaborate and share data and intelligence to ensure well-rounded efforts to stop illicit actors.
Compliance officers should also closely examine clients and counterparties to detect the use of proxies or close associates, as well as professional enablers to move funds. In addition, FINTRAC warns that sanctioned individuals may use alternative financial channels, such as digital assets to move funds and integrate them into the financial system.
Reporting suspicious transactions to FINTRAC is a critical regulatory obligation that helps protect the Canadian and global financial systems, prevent money laundering, terrorist financing, and sanctions evasion. FINTRAC notes in recent guidance that all information in a suspicious transaction report (STR) that helps identify the transaction as suspicious should be included.
FINTRAC adds in its guidance that every person in Canada and every Canadian located outside the country must also disclose to the Royal Canadian Mounted Police or the Canadian Security Intelligence Service the existence of property that is owned or controlled by a designated person, as well as any proposed transactions related to that property.
Canada’s federal government since 2015 has introduced a series of legislative amendments to the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act to strengthen the investigative, enforcement, and information-sharing tools of Canada’s anti-money laundering/counter financing of terrorism regime.
Canada’s 2023 Fall Economic Statement proposes new measures to further safeguard the country’s financial system against financial crimes, including legislative measures aimed at combatting sanctions evasion. These measures, according to FINTRAC, authorize the agency to use its expertise to develop intelligence products and disclose its findings to law enforcement partners, when appropriate, to support investigations.
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