Module 1:

Foundations of AML in the Private Sector

(1.5 hours)

• Global AML frameworks (FATF recommendations and international best practices).
• Canadian AML legislation: PCMLTFA, regulations, and FINTRAC roles.
• Private sector’s role in AML ecosystem (including compliance, reporting, and oversight duties).
• Industry-specific AML obligations (e.g., banks, real estate, dealers in luxury goods, law firms).

Module 2:

Risk-Based Approach & Customer Due Diligence (CDD)

(2 hours)

• Fundamentals of risk-based approach (RBA) and how it shapes AML compliance.
• Client risk rating methodologies and sector-adjusted scoring factors.
• Know Your Client (KYC) and beneficial ownership identification practices.
• Enhanced due diligence (EDD) protocols for high-risk clients (e.g., politically exposed persons, offshore entities, high-cash businesses).

Module 3:

Red Flags, Typologies & Suspicious Activity Reporting (SAR/STR)

(1.5 hours)

• Sector-specific red flags (e.g., real estate purchases with unclear sources of funds, overuse of trust structures in accounting).
• Typologies of money laundering (e.g., smurfing, shell companies, invoice manipulation, trade-based laundering).
• High-risk scenarios involving HNWIs, private lending, consultants, and small business clients.
• STR/SAR reporting obligations, including thresholds, timelines, documentation standards, and FINTRAC submission protocols.

Module 4:

Internal Controls, Monitoring & Investigations

(2 hours)

• Core components of an AML compliance program (policies, procedures, training, internal audits).
• Transaction monitoring technologies, alert generation, and case management.
• Internal escalation, documentation practices, and investigation techniques.
• Roles and responsibilities of compliance officers, internal audit teams, and third-party reviewers.

Module 5:

Case Studies, AML Trends in the Private Sector, and Investigating Risk in Practice

(3 hours) 

• Canadian and global AML enforcement actions involving private firms.
• Industry-specific case studies: fintech companies, financial advisors, real estate agencies, private equity firms, and SMEs.
• Challenges in servicing high-net-worth individuals (HNWIs), family offices, and unregulated professions.
• Emerging AML risks: use of cryptocurrencies, ESG-linked risks, AI-enabled fraud, and digital onboarding vulnerabilities.