Posted on March 17, 2015
If you work in the field of anti-money laundering compliance then this trend should really cause you some concern. In the last few months CAMLOs in the U.K. and the U.S.A. have been held personally responsible by regulators for the deficiencies in their respective institutions. In the U.K. a CAMLO was personally assessed a fine of £38,000 (over CAN $70,000) and banned from future employment in the AML compliance field (as a CF10) because of his inability to bring his investment firm into compliance. The U.S. Securities Exchange Commission charged a CAMLO for altering a document to make it appear as if she had conducted a more thorough review on suspicious transactions (broker trading) than she actually had. In each case investigators and regulators had already been conducting active investigations into the CAMLO's entity. Read their stories here: http://www.fca.org.uk/news/fca-fines-and-prohibits-mr-stephen-bell and http://www.sec.gov/News/PressRelease/Detail/PressRelease/1370543175814#.VQhQhoUfsb0
All this goes to show that compliance officers hold a critical position in the national and international anti-money laundering arena. Canada is probably not ready to charge individual CAMLOs for their firm's deficiencies. However, trends spread and it would be reckless to ignore the enforcement patterns of our two closest cousins.
Canada's DPMS ought to take special note of this trend. Most of Canada's DPMS are small, independent family run businesses with tight margins, no room for squandered resources, and insufficient time and expertise to start up a compliance program from scratch. When it comes to your AML compliance regime don't risk personal or corporate liability by trying to patch together a program from a generic off-the-shelf product sold over the internet. That simply won't do and FINTRAC has been very clear about the inadequacies of the cut-and-paste approach.
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