A Robust AML Compliance Program must have a comprehensive 2-year review
FINTRAC's Guidance states: "A two-year effectiveness review is an evaluation that must be conducted every 2 years (at a minimum) to test the effectiveness of the elements of your compliance program (policies and procedures, risk assessment, and ongoing training program and plan). You must start your effectiveness review no later than 2 years (24 months) from the start of your previous review. You must also ensure that you have completed your previous review before you start the next review.
The purpose of an effectiveness review is to determine whether your compliance program has gaps or weaknesses that may prevent your business from effectively detecting and preventing money laundering, terrorist activity financing and sanctions evasion.
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Your effectiveness review will help you determine if:
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your business practices reflect what is written in your compliance program documentation and if you are meeting your requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations
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your risk assessment is effective at identifying and mitigating the money laundering, terrorist activity financing and sanctions evasion risks related to your clients, affiliates (if any), products, services, delivery channels, new developments or technology, and geographic locations where you do business."
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in addition, it tests if your business has an effective on-going training program and plan for its staff.
About Us
Ron McKave is a trusted expert in Anti-Money Laundering (AML) compliance, with over 23 years of experience in proceeds of crime for the Canadian government (Recently retired from Public Service September 2024). For a decade, Ron worked at FINTRAC, Canada’s financial intelligence unit, conducting examinations and ensuring compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its Regulations.
Prior to FINTRAC, Ron worked 13 years for the CRA Investigations Division, Special Enforcement Program, where he conducted forensic audits on individuals who earned income from the proceeds of crime.
With a deep understanding of AML regulations and extensive hands-on experience, Ron has successfully helped businesses navigate complex compliance requirements. His work has spanned the real estate sector as well as a variety of other industries. Ron's commitment to excellence and thorough attention to detail make him a trusted partner for businesses seeking to stay compliant with AML laws.
