The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide the Department of Finance Canada (Finance) with comments on the Regulations amending certain regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act and, as a whole, the Consultation).
As background, PMAC represents over 250 investment management firms that collectively manage over $1.8 trillion in assets under management, all of whom are registered as portfolio managers with one or more of the Canadian Securities Administrators (CSA). PMAC members manage investment portfolios for private individuals, institutions, foundations, universities and pension plans.
PMAC’s members are financial entities that generally fall under the definition of “securities dealers” and are required to comply with specific obligations under the Act, including anti-money laundering and anti-terrorist financing (AML)-specific know your client identification requirements, training staff on AML issues, implementing and maintaining a AML compliance program, and maintaining records in connection therewith.
PMAC is supportive of Finance’s Consultation and believes that certain of the proposed amendments to the Act will result in a welcome reduction in the AML compliance burden, while maintaining a principles-based approach to AML risk mitigation, monitoring and reporting.
PMAC’s comments on the proposed amendments to the Act that are most relevant to our members, as financial entities, are set out below for your consideration.