Anti-Money Laundering & Anti-Terrorist Financing (AML & ATF) Committee - Meeting Minutes - March 4, 2015

Sep 2, 2026

Meeting minutes of the Anti-Money Laundering & Anti-Terrorist Financing (AML & ATF) Committee dated March 4, 2015, covering a FINTRAC briefing on AML/ATF in Canada. Topics include FINTRAC’s mandate and interactions with the FATF, stakeholder roles, and regional compliance operations. Discussion details reporting and record-keeping obligations for accounting sector reporting entities, core compliance-regime components, risk assessment and risk-based approaches, and how FINTRAC selects and performs compliance examinations.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages7

Reading Time18 min

AccessFree to download

Meeting Overview

Committee Welcome and Introductions

FINTRAC Briefing

FINTRAC Mandate and Stakeholder Roles

Compliance Regime and Obligations

Risk Assessment and Record Keeping

Compliance Examination Approach and Results

| Committee/Study Group:
Comité/Groupe d’étude:
Meeting Date/ Date de réunion:
Chair / Président(e):
CPA Canada / CPA Canada:
Guests / Invités: | Anti-Money Laundering & Anti-Terrorist Financing Committee
March 4, 2015
Matthew McGuire
Marial Stirling Gigi Dawe
Cheryl Charbonneau, Recording Secretary, Minutes by Minute
Lisa Douglas, FINTRAC Frank Lofranco, FINTRAC | Attendees/
Membres présents:
Regrets / Regrets: | Michael Ecclestone Bruce McMeekin Michael Pawliw
Barry Hawn (by phone)
Gene DiMira Monica Stark | | --- | --- | --- | --- | | Discussion | Action | | --- | --- | | Welcome and Introductions
Matthew McGuire
The Chair welcomed everyone to the first meeting of the new Anti-Money Laundering & AntiTerrorist Financing (AML & ATF) Committee. | | | FINTRAC Session
Frank Lofranco and Lisa Douglas
Representatives from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Frank Lofranco (Deputy Chief Compliance Officer and Regional Director, Central Region) and Lisa Douglas (Regional Compliance Manager), presented an overview of FINTRAC’s work regarding AML and ATF in Canada. Highlights included:
􏂷 FINTRAC’s mandate.
􏂷 Interactions with the Financial Action Task Force (FATF) .
􏂷 Roles and responsibilities of the stakeholders.
􏂷 Regional operations and the compliance sector. | | | Discussion | Action | | --- | --- | | 􏂷 Triggering activities and obligations for the accounting sector – reporting entities engaged in triggering activities have obligations regarding reporting, record keeping, client identification, third party determinations and a compliance regime. Quality reporting is essential to ensure compliance with the legislation.
􏂷 Compliance regime (Guideline 4)– an effective compliance regime protects an organization and should include a compliance officer, policies and procedures, training, risk assessment, program review, reporting, client ID and record keeping.
􏂷 Risk assessment – an analysis of the organization’s potential threats and vulnerabilities to understand the risks for AML and ATF and be able to focus on high risk areas. A Risk Assessment Methodology is available as guidance for conducting a risk assessment. Sector-specific workbooks, especially for small to medium organizations, are being developed to provide more guidance.
􏂷 Record keeping (Guideline 6)– FINTRAC has not dictated the elements of the record keeping system , but it must be effective.
􏂷 Risk-based approach – in addition to the proposed risk-based approach for reporting entities, FINTRAC determines risk by considering an organization’s risk assessment and history of compliance activities. FINTRAC tailors its activities to focus on areas where thereis the highest risk.
The presentation then focused on the Chair’s request for clarification of a reference in FINTRAC’s 2014 Annual Report regarding its compliance examination findings in the accounting sector:
Accountants and life insurance: These sectors include both large businesses and small or single-person operations. Demonstrating similar compliance behavior, these sectors have displayed gaps in compliance regimes. In order to increase compliance within these two sectors, FINTRAC will continue with assessment and enforcement activities, and will reach out to the broader population through their various associations.
The FINTRAC representatives reviewed the results of its three-year examination review of the accounting sector from April 2012 to February 2015, involving 44 examinations across Canada (some of which were follow-up reviews) . FINTRAC considers several risk factors when determining what reporting entities to examine:
􏂷 Profile of the entity (sector and size)
􏂷 Compliance history
􏂷 Whether there has been reporting in the past
􏂷 Financial intelligence or information from regulators
􏂷 Market share (larger entities are more likely to be selected for an examinat

FAQs

What organization presented the AML/ATF overview to the committee?

FINTRAC representatives presented the overview, including Frank Lofranco and Lisa Douglas.

What compliance regime elements were highlighted for reporting entities?

The briefing emphasized requirements such as a compliance officer, policies and procedures, ongoing training, risk assessment, program review, reporting, client identification, and effective record keeping.

How does FINTRAC decide which accounting-sector entities to examine?

FINTRAC considers factors such as the entity profile (sector and size), compliance history, whether reporting occurred previously, financial intelligence or regulator information, and market share, and it determines whether reviews are on-site or desk-based based on its risk assessment process.

Sep 2, 2026

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