RITA TRICHUR at the Globe does great job at summarizing the sorry state of Anti Money Laundering (AML) regulation and operational compliance.
Globe and Mail Rita quotes FinTRAC CEO CEO Sarah Paquet
She also made another observation: Too many businesses are looking at risks in silos. As she pointed out, operational risk, fraud risk and cyber risk are often intertwined with financial crime such as money laundering and human trafficking.
I can confirm from observation, that the operation of AML administration in Banks is almost limited to a 3 monthly requirement to read the procedures and some complete a brief quiz. I have not seen any of the 5 banks I have known conduct a blind test, an operational audit or any follow up to the 3 monthly exercise.
I cannot compare to other countries but Canada would be an easy prize for bad actors using holding companies, third party assistance, or money movement through established companies.
I fully support Sarahs desire to ramp up oversight though this has been a long time coming.
That oversight needs to have hands on bank audits directly reviewing actual transactions in the threshold group, observation of transactions that are close to the threshold.
Why now? Beyond the regulatory movement coming from FATF there is an immediate pressing need as seen with Binance support to Hamas and US Department of Treasury and Congress Research reviewing support to Hamas and other criminal actors through money transfers and currency conversion.
Bankwatch 