Timing What is the date or range of dates the non-compliance occurred? In order to complete this section, you must fully understand the issue and when it began. The response here should be 1-3 sentences. Issue


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NameTiming What is the date or range of dates the non-compliance occurred? In order to complete this section, you must fully understand the issue and when it began. The response here should be 1-3 sentences. Issue
A typeDocumentation
XXX Company Name

XXX Address (full mailing address)
Financial Transactions and Reports Analysis Centre of Canada
24th floor, 234 Laurier Avenue West
Ottawa ON  K1P 1H7
CANADA

XXX Date

Voluntary Disclosure of Non Compliance & Resolution


Dear XXX Contact Name,

We are writing voluntarily disclose a non-compliance issue and its subsequent resolution.

Provide a brief 1-3 sentence summary of the incident here. This will repeat somewhat in the sections below.

Timing


What is the date or range of dates the non-compliance occurred?

In order to complete this section, you must fully understand the issue and when it began. The response here should be 1-3 sentences.

Issue


How and why did the incident occur?

To complete this section, you must conduct ‘root cause analysis.’ This means figuring out why you were non-compliant. Describe exactly what the issue was, how it happened and why it happened. This is not meant to blame a specific individual, technology or process, but to demonstrate that you understand the problem.

You should state here whether the issue was a “one time” issue or a systemic (reoccurring) issue. In either case, you should describe how you know that. This means that you will need to look back at previous transactions. Describe everything that you have done to make this determination.

Remedy


What action has been taken to remedy the non-compliance issue?

This section may include:

  • Additional staff training or staff bulletins;

  • New or improved software or technology-based solutions;

  • New processes or process improvements;

  • Hiring additional staff;

  • Updates to the compliance program; and/or

  • Any other steps that you have taken or plan to take.

Each measure that you take should have a clear description in its own paragraph. The measures that you take should be directly related to the cause of the issue. For example, if a report was missed because key staff did not understand the 24-hour rule, the Compliance Officer may conduct a training session with key staff.

There should be back-up documentation for all of the steps that you take to remedy the issue. Your back-up documentation does not need to be attached to this letter, but you should be able to show what you’ve done if FINTRAC requests additional information.

Compliance Program


Why, as part of your required compliance program, a review of your policies and procedures did not identify the problem?

This can be a difficult question to answer. Generally speaking, any review that is conducted will include only a sample of your transactions for a period of time. It may be that the transactions(s) not part of the sample or that the transaction(s) happened outside of the review period. If the type of transaction was not tested in the review, make sure that it is included in the next review (and make note of that in this section and in the resolution section of this letter).

FINTRAC Reporting


If applicable, what was the total number of reports, which were not filed, during the period in question?

This section should include the total number and type of missed reports and/or reports that have been corrected and resubmitted.

If there are no missed or corrected reports, keep this section and note that no reporting was missed.

Discovery & Compliance Program


How and when did you discover the problem?

This may repeat a bit from the sections above, and that’s okay. A problem may be discovered by:

  • Customer feedback or complaints;

  • Self-testing or compliance testing;

  • Auditor or AML Compliance Effectiveness Reviewer; or

  • Regulator review (this may be FINTRAC or another regulator that looks at your AML program).

The description should clearly indicate when the problem was brought to the company’s attention.

If a lot of time has passed between the issue coming to light and your resolution, explain why that is the case in this section. Remember that it is important to show that you are committed to compliance. Saying that you were busy with other things is not going to be considered a good reason for a delay; working with staff and your IT providers to be certain that you understood the root cause of the issue and had a plan to remedy it is a good reason.

Resolution


If not already resolved, when do you expect the correct the non-compliance issue?

In this section, describe any additional steps that you will take to resolve the issue and be certain that it does not reoccur. This may repeat some of the content in the previous sections.

Summary & Closing


We are committed to preventing, detecting and deterring money laundering and terrorist financing and compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations. If you require any additional information, please contact us.

Sincerely.

XXX contact person name

XXX contact email address

XXX contact phone number

Template letter developed by Outlier Solutions Inc – www.outliercanada.com

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