The ML/TF Risk Assessment is a mandatory document required under Canadian anti-money laundering legislation for reporting entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). This document must be regularly updated to reflect changes in business operations, risk landscape, and regulatory requirements. It serves as the foundation for an organization's risk-based approach to preventing money laundering and terrorist financing, informing policies, procedures, and controls. The assessment must consider various risk factors including, but not limited to, products and services, delivery channels, geographic exposure, and client characteristics. The document demonstrates compliance with FINTRAC guidelines and helps organizations allocate resources effectively based on identified risks.
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1. Executive Summary: Overview of the key findings, overall risk rating, and major recommendations
2. Introduction and Scope: Purpose of the assessment, scope, methodology, and regulatory framework being addressed
3. Business Profile: Detailed description of the organization, its products/services, channels, and business model
4. Risk Assessment Methodology: Explanation of risk rating criteria, scoring system, and assessment approach
5. Products and Services Risk Analysis: Assessment of risks associated with different products and services offered
6. Geographic Risk Analysis: Evaluation of risks associated with jurisdictions where the business operates or transacts
7. Client Risk Analysis: Assessment of customer base risks, including high-risk client categories
8. Distribution Channel Risk Analysis: Evaluation of risks associated with delivery channels and payment methods
9. Other Risk Factors: Analysis of other relevant risk factors such as operational risks and regulatory changes
10. Risk Control Measures: Description of existing controls and their effectiveness in mitigating identified risks
11. Gap Analysis: Identification of areas where current controls may be insufficient
12. Conclusions and Recommendations: Overall risk rating and specific recommendations for risk mitigation
1. Transaction Pattern Analysis: Detailed analysis of transaction patterns and anomalies, recommended for financial institutions and payment service providers
2. Third Party Risk Assessment: Evaluation of risks associated with third-party service providers and partners, relevant for businesses with significant outsourcing
3. Digital Services Risk Assessment: Specific analysis of online and digital service risks, important for businesses with significant digital presence
4. Cross-Border Activities Assessment: Detailed analysis of international operations and transactions, necessary for businesses with international exposure
5. Sanctions Compliance Assessment: Specific evaluation of sanctions compliance risks, important for international businesses or those dealing with high-risk jurisdictions
6. Historical Incident Analysis: Review of past ML/TF incidents and effectiveness of responses, relevant for established businesses
1. Appendix A - Risk Rating Matrix: Detailed risk scoring criteria and methodology
2. Appendix B - Geographic Risk Ratings: Comprehensive list of geographic risk ratings by country/region
3. Appendix C - High-Risk Client Categories: Detailed definitions and criteria for high-risk client classifications
4. Appendix D - Control Framework: Detailed documentation of all AML/CTF controls
5. Appendix E - Risk Assessment Questionnaire: Questionnaire used for gathering risk assessment data
6. Appendix F - Action Plan: Detailed implementation plan for recommended improvements
7. Schedule 1 - Statistical Analysis: Quantitative analysis of transaction data and risk indicators
8. Schedule 2 - Regulatory Requirements Matrix: Mapping of regulatory requirements to control measures
Authors
Relevant legal definitions
Clauses
Relevant Industries
Banking and Financial Services
Securities and Investments
Insurance
Credit Unions
Money Services Businesses
Real Estate
Casino and Gaming
Cryptocurrency and Digital Assets
Professional Services
Precious Metals and Stones Dealers
International Trade and Commerce
Financial Technology
Relevant Teams
Compliance
Risk Management
Legal
Internal Audit
Operations
Financial Crime Prevention
Due Diligence
Senior Management
Board of Directors
Training and Development
Customer Onboarding
Transaction Monitoring
Regulatory Reporting
Relevant Roles
Chief Compliance Officer
AML Compliance Manager
Risk Management Director
Compliance Analyst
Money Laundering Reporting Officer
Chief Risk Officer
Regulatory Compliance Specialist
Financial Crime Analyst
Head of Internal Audit
Chief Executive Officer
Operations Director
Legal Counsel
Financial Controller
Compliance Training Manager
Due Diligence Officer
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