Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), ivari must now submit a suspicious transaction report to FINTRAC if there are reasonable grounds to suspect that a financial transaction, or attempted transaction, is related to or is an attempt to evade sanctions.

What does this mean for you as an advisor?

This means that you are now required to report to ivari any financial transaction(s) or attempted financial transaction(s) which may be related to Sanctions Evasion using the Unusual Activity Reporting (UAR) tool in webcappow. This is in addition to the existing reporting obligations relating to money laundering and terrorist financing.

Understanding sanctions

Simply put, sanctions are limitations. For example, Canadian sanctions limit what people in Canada, or Canadians abroad, can do with certain foreign countries, organizations, or individuals. Sanctions can target specific places or people and can include measures like banning trade, financial transactions, or other economic activities between Canada and the targeted entities. Evading sanctions refers to an attempt to avoid these limitations.

For additional information on Sanctions Evasion please refer to the Government of Canada website: Special Bulletin on financial activity associated with suspected sanctions evasion (canada.ca)

To learn more about the UAR tool in webcappow, please visit the Compliance & legal page or see our UAR Q&A.