AML Reminders - May 2026
As we approach the two-year mark of the anniversary of AML/ATF compliance under FINTRAC, the brokerage has been undergoing a review to cover off points of emphasis from the regulator in preparation for the bi-annual effectiveness audit. While we’re quite pleased with agents’ performances thus far, there are a few areas we’d like to point out in order to ensure we’re in the best position going forward.
When Are You Risk Rating?
As a reminder, you need to risk rate any file for which we established a business relationship. That means when you check ID or pull credit. The deal doesn’t have to fund to require your AML compliance.
We understand that you might not have all the information up front - your risk rating can change. As you get more information, make sure you’re considering all the variables. The Automated Scorecard on the FCFunding.ca resource page is a great tool
So … You Have a High-Risk File
High risk files are not a reflection of your borrower or the quality of the deal - it’s about capacity for money laundering/terrorist financing activities. There are very few positions that are “Hard Stop” - meaning we can’t proceed with a deal
You need to document due diligence. Oftentimes these are things you’ll do anyway, but you need to put extra care into them and make sure it’s explicit - if someone’s auditing a file, they should know exactly what you’ve done.
Think about it in terms of answering the question: What steps have you taken to check that there’s no evidence of money laundering? This can include checking income (particularly for BFS clients), verifying sources of down payment to make sure they are in line with the information you have, and making sure the client’s “story” checks out - do all the details add up?
Make sure you’re using two different methods to verify ID.
Take Advantage of Your Resources
FC Funding has a compliance and AML team that’s here to help! If you have questions, or need support (whether generally or on a specific deal), reach out - the earlier the better!
For those who missed it, there was an AML-specific call on the April 14 Agent Accelerator call - this is available on the FC Funding website if you want to review topics in greater detail.