Mortgage companies

Mortgage Brokers, Lenders and Administrators are now regulated under the PCMLTFA. This means that the mortgage sector in Canada is now covered by federal anti-money laundering legislation. Mortgage companies are now expected to have a compliance plan in place.

Now is the time to take action to get your compliance plans started, to mitigate future risk. Contact one of our aml experts today for more information or if you have any questions.

Check out our reference guide for the mortgage sector if you are an employer that is a broker, lender, or administrator, and you are unclear about your anti-money laundering regulatory obligations.

And, Watch a video below that outlines what these changes mean for the mortgage sector and the best-practices for developing an AML compliance program.

Mortgage companies - What you need to know

You must implement a compliance program that includes:

• Naming a Compliance Officer

• Documenting your anti-money laundering risk and management plan

• Documenting your compliance policies and procedures

• Documenting a training plan and delivering training to your staff

• Conducting a review of the effectiveness of your program every 2-years

For each individual borrower you must:

• Verify the borrower’s identity

• Assess the borrower’s risk

• Take reasonable measures to identify the involvement of any third parties

• Take reasonable measures to determine the politically exposed status of the borrower

• Keep a record of the purpose and intended nature of your relationship with the borrower

• Conduct enhanced due diligence for high-risk borrowers

For each entity borrower you must:

• Verify the borrower’s identity

• Verify the identity of the borrower’s signing officer

• Obtain and confirm the entity’s beneficial ownership structure

• Assess the borrower’s risk

• Take reasonable measures to identify the involvement of any third parties

• Keep a record of the purpose and intended nature of your relationship with the borrower

• Conduct enhanced due diligence for high-risk borrowers

And don’t forget…

Ongoing monitoring

Remember that you need to keep monitoring the relationship with your clients for five years after you stop dealing with them.

Reporting to FINTRAC

If you notice an anomaly relating to a client’s behaviour, the nature of the deal, the source of funds, or any information that the client has provided to you, you need to review it to understand if there is a reasonable explanation for the anomaly.  If you’re not able to conclude that there is a reasonable explanation, you must report it to FINTRAC.

At The AML Shop, our experts work with some of Canada's largest mortgage networks. If you are a mortgage company that needs help navigating AML contactus@theamlshop.ca to get in touch with an expert.