Due diligence checklist, Canada
PCMLTFA (FINTRAC): what to ask a vendor
Proceeds of Crime (Money Laundering) and Terrorist Financing Act. FINTRAC. Reporting entities verify identity, keep records and report to FINTRAC under the Act and Regulations.
What it is
Reporting entities verify identity, keep records and report to FINTRAC under the Act and Regulations.
Who it applies to
Applies to every financial institution in Canada, when procuring financial crime and fraud, payments, core banking, digital banking.
What to ask a vendor, and the evidence to request
| # | Ask the vendor for | Evidence to request |
|---|---|---|
| 1 | Identity verification by the methods the Regulations allow | The identification and verification methods supported, the rules they follow, and the record kept for each check. |
| 2 | Suspicious transaction, large cash and electronic funds transfer reporting to FINTRAC | The hosting regions and a data flow description naming every country data is stored in or processed from, and the transfer mechanism for anything leaving the country. |
| 3 | Record keeping to the Regulations' retention periods | The retention schedule showing how long records are kept, where, and how they are retrieved for the institution or a regulator. |
In every case
- A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
- Which named customers the vendor already serves under this regime, as references you may call.
This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.
Next
- Every checklist, by country
- What a market scan is and how to run one
- Have Vederca run the procurement: the regime goes into the register as a must-have