Kahnawake
AML/CFT & MLRO
Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) are critical regulatory frameworks designed to combat financial crimes such as money laundering and the financing of terrorism.
In Kahnawake, AML and CFT regulations are governed by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and overseen by Canadian federal regulators such as FINTRAC. Businesses in Kahnawake, particularly within the iGaming sector, are required to implement robust measures such as customer due diligence, transaction monitoring, risk assessment and reporting. These frameworks ensure Kahnawake maintains its reputation as a trusted jurisdiction for iGaming operations.
As compliance requirements tighten and risks evolve, having a comprehensive and effective AML and CFT framework is essential for protecting your business. IGA Group is here to guide you through Kahnawake’s regulatory requirements, helping you achieve compliance and long-term success.
Requirements
| Obligation | Description | |
|---|---|---|
 | Risk Management | Conducting regular scrutiny of financial transactions to detect unusual or suspicious patterns. |
 | Reporting | Filing Suspicious Activity Reports (SARs) with relevant authorities to flag any suspicious activity. |
 | Training & Awareness | Ensuring employees are fully trained on AML/CFT regulations and how to detect potential risks. |
 | MLRO Oversight | The MLRO is responsible for overseeing AML/CFT policies, conducting risk assessments, monitoring transactions and reporting any suspicious activities to authorities. |
 | Annual Audit | Regularly auditing the compliance systems to ensure they are operating effectively and in accordance with regulations. |
 | Business Risk Assessment | Evaluating potential risks faced by the business, including the risk of money laundering and terrorist financing. |
 | Policies & Procedures | Developing and maintaining policies and procedures to prevent and detect money laundering and terrorist financing. |
 | Internal Controls & Compliance Management | Implementing internal controls to monitor compliance with AML/CFT regulations and ensuring ongoing regulatory adherence. |
Our Services
A Comprehensive Approach to Compliance
At IGAML (IGA Group), we provide a full range of services to support your business at every stage of compliance.
Our offerings include customer due diligence, risk assessments, MLRO services, audits, training and reporting to ensure your compliance framework is effective, efficient and fully aligned with local and international regulations.
The services are structured under key thematic areas as follows:
01
Compliance Audits & Assurance
Objective: independent assessment and assurance of AML/CFT compliance to identify risks, ensure controls are effective and recommend improvements.
AML External Audits
Our external audits are designed to provide an independent, comprehensive assessment of your organisation’s compliance framework to ensure alignment with both local and international standards. We offer two types of audits:
- Full Audits: a comprehensive 360-degree review of all systems, processes and procedures, including an evaluation of client files, transaction monitoring and control effectiveness. The full audit identifies weaknesses or gaps, with remediation plans to address any deficiencies.
- Thematic Audits: focused on specific areas of compliance, such as transaction monitoring, risk-based approaches or enhanced due diligence. Thematic audits provide targeted insights and practical recommendations to strengthen key aspects of your AML/CFT programme.
02
Risk Assessment & Monitoring
- Business Risk Assessment (BRA) Creation and Drafting: develop a detailed evaluation of the inherent risks in your operations and ensure suitable mitigation measures are in place.
- Client Risk Assessment (CRA): Design and Development: evaluate clients to determine their risk level, ensuring appropriate due diligence is applied.
- Setup of Transaction Monitoring Rules, Thresholds and Limits: configure systems to identify potentially suspicious activities using customised monitoring criteria.
- Ongoing Monitoring of Clients: continuous evaluation of client activities to detect changes in their risk profile that may require increased scrutiny.
- Enhanced Due Diligence Reports: in-depth investigation for high-risk clients or transactions, providing comprehensive insights to mitigate risks.
03
MLRO Services & Support
- MLRO Appointment: appoint experienced MLROs with a deep understanding of the regulatory landscape in Kahnawake, to manage your compliance framework.
- MLRO Shadowing Services: step-by-step support for newly appointed MLROs to ensure they meet statutory requirements. Our shadowing services include:
– Regular assistance in both internal and external reporting
– Guidance on drafting STRs/SARs
– Ad hoc support based on specific cases or risk scenarios
– Calls and Q&A sessions as needed
– Ensuring policies, procedures and controls (AML/CFT manual) are effective and up-to-date
– Assistance in drafting Business Risk Assessments (BRA) prior to REQ submission
– Yearly training and upskilling opportunities
04
Outsourced Managed Services
- Know Your Customer (KYC): we provide end-to-end client onboarding, identity verification and ongoing compliance monitoring. This includes customer due diligence and risk assessments to ensure that your client relationships meet all regulatory standards and minimise risks.
- Know Your Business (KYB): A comprehensive evaluation of your business partners to reduce exposure to third-party risks. This includes the verification of ownership structures, financial analysis and ongoing monitoring to ensure that all counterparties meet compliance requirements, protecting your organisation from hidden liabilities.
- Ongoing Compliance Management: IGAML’s team offers assistance with all day-to-day compliance activities, such as transaction monitoring, due diligence updates and regulatory reporting. This ensures that your business remains up-to-date and fully compliant with the latest standards, enabling you to confidently navigate the evolving regulatory landscape.
05
Regulatory Review & Representation
Objective: assistance with preparation for regulatory reviews and representation during interactions with regulatory bodies.
- Assistance and Preparation for FINTRAC Compliance Reviews: detailed preparation, including mock audits, reviewing policies and providing practical recommendations to address any gaps.
- Representation During Compliance Reviews by FINTRAC/Kahnawake Gaming Commission: representation during compliance reviews by FINTRAC or the Kahnawake Gaming Commission to ensure that all queries are addressed effectively and efficiently.
- Remediation Consultancy: address any findings from compliance reviews with step-by-step remediation plans to close gaps and ensure full compliance.
06
Governance, Manuals & Training
Objective: develop documentation, internal policies and knowledge to maintain an effective compliance framework.
- AML/CFT Manuals and Ancillary Policies: customised manuals to provide employees with the practical guidance needed to adhere to AML regulations.
- AML/CFT Training for Different Levels of the Organisation: tailored training sessions for every level of the organisation, ensuring staff understand their responsibilities in preventing financial crime.
- Assistance in Drafting Effective Policies and Procedures: develop or update internal policies and procedures to ensure they align with regulatory standards and are effective.
- Preparation of the Risk Evaluation Questionnaire (REQ): assist in drafting the REQ for submission to regulators, accurately reflecting your business’s risk profile.
07
Investigative Due Diligence & Analytical Services
Objective: comprehensive due diligence for clients and partners, and insight-driven analytics for compliance decision-making.
- Investigative Due Diligence: in-depth investigation into business partners or clients, examining financial records, ownership structures and relationships to identify any potential risks.
- Analytical Reporting and Research Services: data-driven insights to support decision-making in compliance, identifying patterns and assessing risks to help mitigate potential threats.
08
Legal Advisory & Consultancy
Objective: providing expert legal guidance to address regulatory challenges and ensure AML/CFT compliance.
- Legal Advisory Services: support in interpreting and applying AML/CFT regulations, guidance on regulatory changes and compliance-related issues.
- AML/CFT Governance and Management Consultancy: establish effective governance structures, define compliance roles and promote a culture of compliance within your organisation.
Why Choose IGAML?
Local Insight
With in-depth knowledge of Kahnawake’s regulatory framework, we ensure that your compliance measures align with both local and international standards.
Comprehensive Solutions
Our services span the entire compliance spectrum, from external audits and MLRO services to outsourced KYC/KYB management.
Personalised Support
We tailor our solutions to your specific needs, ensuring that every aspect of your compliance programme is optimised for efficiency.
Frequently Asked Questions
What is an AML External Audit and why is it important?
An AML External Audit is an independent assessment of your organisation’s AML/CFT controls to ensure they are effective in preventing financial crime. It helps identify any weaknesses and provides recommendations for improvement, ensuring compliance with regulations.
What is the difference between a Full Audit and a Thematic Audit?
A Full Audit is a comprehensive evaluation of all systems, processes, and controls within your organisation, while a Thematic Audit focuses on specific areas, such as transaction monitoring or enhanced due diligence, to address particular risks.
Can IGAML provide an MLRO for my business?
Yes, IGAML can appoint a dedicated Money Laundering Reporting Officer (MLRO) to manage your AML/CFT responsibilities and ensure compliance with regulations.
What is MLRO Shadowing and who can benefit from it?
MLRO Shadowing is a support service for newly appointed MLROs, helping them understand and fulfil their responsibilities effectively. This service is ideal for organisations that need additional expertise during the transition period.
What are the benefits of outsourcing AML/CFT services to IGAML?
Outsourcing to IGAML allows you to leverage our expertise, scalability, and advanced compliance technologies. It reduces overhead costs, ensures compliance with the latest standards and allows you to focus on your core business activities.
What does IGAML's managed KYC/KYB service include?
Our managed KYC/KYB service includes onboarding clients, transaction monitoring, enhanced due diligence, and ongoing compliance management to ensure full adherence to AML regulations.
How often should AML/CFT training be conducted?
AML/CFT training should be conducted at least annually, with additional training provided when regulations change or when employees assume new roles that involve compliance responsibilities.
How can IGAML help me prepare for an FIAU compliance review?
We offer specialised support to help you prepare for FIAU compliance reviews, including documentation review, risk assessments and comprehensive mock reviews to ensure your organisation is fully prepared.
What is a Risk Evaluation Questionnaire (REQ) and why is it important for compliance?
The Risk Evaluation Questionnaire (REQ) is a tool used to assess the risk levels associated with your business activities. It helps regulatory authorities understand your risk profile and ensures that you have the appropriate AML/CFT controls in place.
Need assistance?
Whether you have queries, need further assistance or would like to request a quote for any of our services, please don’t hesitate to contact us.
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