On July 10, 2019, the Department of Finance released its amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). The amendments, which were first proposed back in June 2018, are designed to help Canada keep pace in an ever-changing money laundering (ML) and terrorist financing (TF) environment and ensure our regulations are aligned with those around the world.
While current reporting entities—including financial institutions, credit unions, casinos, money services businesses (MSBs), dealers in precious metals, real estate brokers or sales representatives, insurance companies and others—will inevitably be impacted by these changes, they’re not an isolated group. In fact, many industries and businesses that previously did not fall under PCMLTFA regulations will now find themselves subjected to client identification, recordkeeping and reporting requirements—namely, virtual currency businesses, foreign money services businesses (FMSBs) and businesses that both issue and sell prepaid cards. In some cases, determining whether you fall into one of these categories may not be clear, particularly since the world of virtual currency is constantly evolving.