TI Canada Coalition Response to AML Consultation 2023

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Written By TI-Canada

Our response to the AML consultation is finally out

TI Canada, together with our End Snow Washing Coalition partners Publish What You Pay Canada and Canadians for Tax Fairness, have together provided a submission to the Department of Finance in response to their Consultation on Strengthening Canada's Anti-Money Laundering and Anti-Terrorist Financing Regime.

Our policy recommendations focus on:

  • Beneficial ownership transparency for companies, trusts, partnerships, and real property.

  • Ensuring the legal profession is not a weak link Canada’s AML regime. 

  • The mandate, and structure of the proposed Canada Financial Crimes Agency (CFCA)

  • Expanding sectors to be covered in the PCMLTFA, emphasizing real estate and others.

  • Exploratory work on GTOs, UWOs, and PEPs/HIO database

  • Broader information sharing from FINTRAC

  • Penalties exceeding the cost of doing business

  • National security and public safety considerations

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