Canada’s anti-money laundering regime draws one line for correspondent banking that leaves no room for a risk-based judgment call. Under subsection 9.4(2) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, no person or entity may have a correspondent banking relationship with a shell bank. FINTRAC’s correspondent banking guidance explains the pre-entry, record-keeping…
A reloadable open-loop card that a customer can top up to $1,000 sits on top of a prepaid payment product account, and Canada’s financial intelligence unit gives that account the same anti-money-laundering weight as a chequing account. FINTRAC’s prepaid payment products guidance came into effect on 1 June 2021. Under the PCMLTFA and its regulations,…
A Canadian bank with a branch in Singapore falls within section 9.7; a life insurance company’s foreign subsidiary is covered only if it carries out similar activities and is wholly owned or consolidated with the company; and a securities dealer’s affiliated London entity can trigger section 9.8 if the statutory affiliation test is met. Canada’s…