FINTRAC Correspondent Banking Requirements: A Canadian Compliance Guide
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…