Thanks to Lawrence Brendel of Forest of Jewels in Edmonton who
has offered to share his FINTRAC experience with The Toddwaz Report.
Hi Todd,
My FINTRAC Compliance Examination was conducted on Friday
morning and didn’t take the five hours that was noted in their letter to me. In
fact, the compliance officer was here for less than an hour. The whole process
ran smoothly and she was very pleasant to work with.
FINTRAC gave me a month to prepare for the examination but
of course I left it to the last minute. They requested two written documents
from me in preparation for the examination. First were my store’s policies and
procedures for compliance with PCMLTFA (Proceeds of Crime Money Laundering and
Terrorist Financing Act) and second was a risk based assessment pertaining to
the level and types of risk that are specific to my business. I was supposed to
send copies of these documents to the compliance officer 5 days before the exam
but I forgot to do this. This failure was noted on my file. I decided that it
would be in my best interest to be fully prepared on Friday morning. I was.
I thought I was quite diligent in writing my store’s
Compliance Regime but at the end of the exam I was noted for a couple of
deficiencies. One was an omission in how to deal with Terrorist Property.
“What?” I asked the compliance officer. “How would I be able to distinguish
this from regular property? Give me some examples?” She wasn’t too clear in her
answer but I still need to have a written procedure for dealing with it. My
deficiencies will be outlined in a forthcoming letter and I will need to
address them.
It was also mentioned to me before the exam that FINTRAC
wanted to see my bank statements specifically relating to cash deposits. I
guess I didn’t hear or read that but I didn’t have them with me at exam time.
However, the compliance officer was satisfied with viewing the monthly sales
reports on my computer. She reviewed the last 6 months.
The Canadian Jewellery Association has an Anti-Money
Laundering and Compliance Kit on their website under “Members Area”. I strongly
recommend reading it and using it for staff training. It outlines what FINTRAC
is about and what is required in your policies and procedures and your risk
assessment. I would like to thank the CJA and JVC for putting this kit
together. It is a great aid.
The Compliance Exam and the preparation leading up to it
were not an unpleasant experience. My only regret is that I did not have time
for a coffee with Todd but I’ll hit him up for a free one next time!
Lawrence Brendel
Forest of Jewels, Edmonton