What does as soon as practicable mean to each of them when filing STRs and how to apply it in an AML Compliance Regime

On June 1, "2021 the PCMLTF Regulations changed the prescribed timeline for filing STRs from "within 30 days" to "as soon as practicable. FINTRACs expectation as published in Reporting suspicious transactions to FINTRAC (https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/Guide3/str-eng) states;

"As soon as practicable is interpreted to mean that you have completed the measures that have allowed you to determine that you reached the RGS threshold and as such the development and submission of that STR must be treated as a priority. FINTRAC expects that you are not giving unreasonable priority to other transaction monitoring tasks and may question delayed reports. The greater the delay, the greater the need for a suitable explanation. STRs can be complex, yet you must treat them as a priority and ensure they are timely; you must also complete the measures that enabled you to conclude that you have RGS the transaction is related to the commission of an ML/TF offence before you submit the report to FINTRAC."

While this is all great in theory, many Regulated Entities, including MSBs, still struggle to define what a is “reasonable priority” for filing STRs and how it should be translated into its overall AML Compliance Regime.

In this session you will hear from several industry experts, Rodney McInnes (Outlier), Dwayne King (Grant Thornton), Marcelle Dadoun (theAMLShop), and Joseph Iuso (Bitbuy)

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