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Money laundering is a global issue which is illegal, unethical and harmful. In Canada, it poses threats to our national reputation, economy, and society. CPA Canada recognises these threats and contributes to federal policy development. On behalf of the profession and in the public interest, we engage with the federal government in efforts to strengthen Canada’s anti-money laundering regime and present the Strategic Framework for AML.

Elements of such a strategic framework, in our view, include:

• Corporate transparency - increased corporate ownership transparency via improved access to beneficial ownership information, while maintaining the ease of doing business in Canada
• Whistleblowing framework - a national framework for the reporting by and protection of whistleblowers, instead of the current patchwork quilt of provisions at the federal and provincial government levels
• Organisational compliance programs - development of new, national standards outlining expectations for organisational integrity and compliance programs
• Enforcement - development of enhanced, transparent, and streamlined processes for law enforcement, prosecutors, and other parties to address allegations of misconduct

The regulations are changing at warp speed, and the stakes for complying with applicable regulations continues to increase. Risks for doing business with the wrong third party are financial, commercial and reputational in nature and pose ongoing compliance concerns.

• Sanctions - if ownership is 50% or higher, either solely or in aggregate by one or more sanctioned subjects, that entity is sanctioned. Even below that 50% ownership threshold, a red flag should be raised and risk assessment performed.
• Due Diligence, Organizations and Staffing -  compliance responsibility does not end after an initial business partner screening. Responsibilities for full compliance, organizational reputation and professional peace of mind may be at stake.
• Export Controls - managing the operational compliance of export controls in such an unstable environment is not for the inexperienced trade compliance or supply chain manager. 
• Sanctions Compliance - the logistics of delivering products to and from Russia are now more complicated as shipping ports around the Black Sea have closed, airfreight services by most carriers has been suspended and Russian airspace is closed. For companies still conducting business with Russia, getting paid is becoming all but impossible.