Canada's 2008-2009 Changes to Reporting Entity Obligations

Changes to Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Phase 1 changes of the regulations affect reporting entity obligations (including reporting, record keeping, client identification and implementing a compliance regime). These changes were published in June 2007 and came into effect on June 23, 2008. A second phase of changes was published in December 2007 setting out the requirements for new sectors (British Columbia notaries, legal counsel and legal firms, and dealers in precious metals and stones). They will come into effect December 30, 2008. A third phase of changes was published in February 2008 dealing with new requirements for real estate developers effective February 20, 2009 and additional requirements for casinos effective September 28, 2009. A fourth phase of changes was published in June 2008, mostly about administrative monetary penalties, record keeping and client identification exemptions, and record keeping time frames. The changes affecting administrative monetary penalties will be effective December 30, 2008. The rest are effective June 23, 2008. (Details are available on the FINTRAC website.)