Jurisdictional Framework — Canada
The Canadian banking framework
Regulated primarily by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act — enforced by FINTRAC, with prudential oversight from OSFI. A regime that has moved decisively from remediation to penalization.
FINTRAC's escalating enforcement
The PCMLTFA sets the obligations; FINTRAC now enforces them with Administrative Monetary Penalties reaching tens of millions of dollars — including against Tier 1 banks. The failures are remarkably consistent: inadequate Suspicious Transaction Reporting and delayed large cash or electronic funds transfer reporting. OSFI's updated Guideline B-8 adds prudential teeth, tying integrity and security expectations directly to ML/TF risk.
Key practitioner focus areas
- —EFT reporting: strict adherence to the 24-hour rule for aggregating SWIFT and wire transfers.
- —Correspondent banking: enhanced due diligence on foreign respondent banks clearing USD or CAD.
- —High-risk clients: banking Money Services Businesses safely rather than de-risking them blindly.
- —Interac & e-transfer: real-time rails compress the window between placement and layering — monitoring must keep pace.
Canadian typologies
- —The Vancouver Model: capital flight laundered through casinos and real estate via correspondent accounts.
- —Snow washing: exploiting Canada's clean reputation and historically opaque corporate registries for legitimacy.
- —Trade-based laundering: misinvoicing and letters of credit moving value across borders disguised as commerce.
Practitioner Note
Canada's credit union system carries the same PCMLTFA obligations as the Big Six with a fraction of the compliance headcount. Proportionality is earned through documentation— a defensible, board-approved risk assessment is what separates a right-sized program from an under-resourced one in FINTRAC's eyes.
Canada
Two decades inside Canadian banking and payments.
QAML's founder led cards and payments at one of Canada's largest credit unions, implemented payment platforms coast to coast, and negotiated portfolio acquisitions with Tier 1 banks.