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Implementing a compliance regime FINTRAC Guideline 4: Implementation of a Compliance Regime explains the requirement for reporting persons and entities to implement a regime to ensure compliance with their obligations under the Act. What do CAs need to do now?

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Implementing a compliance regime FINTRAC Guideline 4: Implementation of a Compliance Regime explains the requirement for reporting persons and entities to implement a regime to ensure compliance with their obligations under the Act. What do CAs need to do now?

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• review the legislation, including related regulations and FINTRAC guidelines; • gain an understanding of what money laundering is and how it works (see below); • identify activities carried out by them or their staff that might be covered by the Act; • implement an appropriate compliance regime. What is money laundering? FINTRAC Guideline 1: Backgrounder defines money laundering as “any act or attempted act to disguise the source of money or assets derived from criminal activity.” Essentially, money laundering is the process whereby “dirty money” – produced through criminal activity – is transformed into “clean money,” the criminal origin of which is difficult to trace. There are three recognized stages in the money laundering process. • Placement involves placing the proceeds of crime in the financial system. • Layering involves converting the proceeds of crime into another form and creating complex layers of financial transactions to disguise the audit trail and the source and owne

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