Compliance Effectiveness Reviews: Testing Your AML Compliance Program
Date: October 8, 2024
Time: 10am PT/1pm EST
Precisely two years after a mortgage lender has begun to operate as a reporting entity under Canada’s Proceed of Crime (Money Laundering) and Terrorist Financing Act the lender must undertake a Compliance Effectiveness Review (CER). This Review dictated by the legislation and FINTRAC Guidance is best described as a process whereby the lender’s AML/ATF Compliance Program is tested for its completeness, applicability to the lender’s business model and whether the program is effective in what it does. These Reviews are not simple checklist audits but multi-level evaluation assessments using detailed and standardized tools to arrive at a statement whether the program is in place as required and whether it is accomplishing what is intended. A CER is not an audit in the classic sense but an evaluation. There is a difference as Chris will show with his description of the various stages and elements that make up a well-done Review.
Speaker: Christopher R. Walker, B.Sc., M. Criminology, CAMLI-PA
Chris is a criminologist with over 45 years of experience across the public and private sector. He has degrees from both, McGill University and the University of Ottawa. He has worked as a forensic psychologist and taught at a variety of post-secondary institutions. He was a senior researcher and policy analyst with Solicitor General Canada in the 1990’s where he managed evaluation, research, and policy pertaining to the federal government’s proceeds of crime and anti-money laundering law enforcement programs.
He is a founding partner and President of About Business Crime Solutions, Inc. — a consulting firm established in 2000 and dedicated to assisting professionals and organizations meet their compliance requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. It can be found at www.moneylaundering.ca.
Chris is also one of the founders of the Canadian Anti-Money Laundering Institute, an organization devoted to the training and education of AML/ATF compliance officers. Chris is chair of the annual National Money Laundering in Canada Conference and considered one of Canada’s authorities when it comes to the application of money laundering compliance programs across a wide variety of business and professional sectors governed by Canada’s AML legislation.