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Bruce McMeekin Law

What Does Recklessly Laundering The Proceeds Of Crime Mean?

In the 2019 federal budget released by Finance Minister Bill Morneau on March 19, the government announced its intention to amend the Criminal Code prohibition against money laundering (s. 462.31(1)) by…
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One Issue FINTRAC Doesn’t Include in its New Suspicious Transaction Reporting Guidance

Failing to file a Suspicious Transaction Report (“STR”) is as serious as it can get when it comes to violations, with penalties that can be assessed up to a maximum…
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What are “Dealers in Virtual Currencies”?

Is it just me? Or, is there really a gaping hole in the draft amendments to the PC(ML)TFA and its regulations when in comes to the intended regulation of digital currency?…
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Government Tables Enabling Legislation for Deferred Prosecution Agreements

A month after it announced as part of the federal budget that it intended to introduce deferred prosecution agreements, the government tabled Bill C-74 on March 26. Through proposed amendments to…
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Deferred Prosecution Agreements

As an alternative to prosecution, the Feds are taking a serious look at bringing in DPAs in situations wherein organizations have committed some financial crimes and corruption offences. They have…
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AML Compliance: Some Perspective About Manulife

I have been reading with interest the press reports criticizing FINTRAC for its decision in 2016 to publish, anonymously, the $1.15 million in administrative penalties levied against a Canadian bank…
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FINTRAC RE-THINKS ITS AMP CALCULATION POLICIES

Following the findings of the Federal Court of Appeal in Canada v. Kabul Farms in May, FINTRAC is undertaking an internal review of its AMP calculation policies. Section 73.11 of the…
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What’s Next For Administrative Monetary Penalties (“AMPs”)?

In July 2015, the Supreme Court released its decision Guindon v. Canada finding that AMPs were not offences attracting the protections contained in s.11 of the Charter. As a result, entities…
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