Compliance Effectiveness Review


Regulatory Requirement

Anti Money Laundering legislation & regulations imposes an obligation on firms to assess the effectiveness of their policies and procedures, training and the organizations risk assessment at least bi-annually (every two years).

Guidelines accompanying the legislation specify that certain steps must be taken to address whether policies and procedures are in place and are being adhered to, and whether procedures and practices comply with legislative and regulatory requirements

Evaluate compliance function including policies and procedures and processes against firm’s obligations under Canadian anti-money laundering and anti-terrorism financing legislation. Compare firm’s documented policies and procedures and processes to the requirements of the PCMLTFL and identify gaps and deficiencies.

Areas Examined

Compliance Structure

Senior Management
Compliance Officer
Risk Based Approach
Risk Mitigation
Policies and Procedures

Effectiveness Review
Operational Compliance
Recordkeeping and Retention
Client Identification

Approach to Engagement – Four Phases

1. Information Gathering
2. Evaluation of Compliance Framework
3. Evaluation of Operational Compliance for period under review
4. Report:
——a. Scope
——b. Methodology
——c. Findings