Blog

Bruce McMeekin Law

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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Advocate Daily: Report highlights FINTRAC’s reach into Canadians’ lives

The latest FINTRAC annual report gives a glimpse into the extensive reach of the Financial Transactions and Reports Analysis Centre of Canada and the significant penalties that businesses can face for…
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AML & ATF Regulation: Unreasonable to Tinker With Reasonable Grounds to Suspect – Proposed Regulatory Changes Increase Regulatory Risk

On July 4 FINTRAC released its proposed amendments to many of the regulations promulgated under the PC(ML)TFA. One of the proposed changes to the PC(ML)TFSTR would amend s.9(2) deleting “that constitutes…
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AML & ATF Regulation: Federal Court Quashes FINTRAC AMP

In considering an appeal from the imposition of an administrative monetary penalty (“AMP”) by FINTRAC, the Federal Court recently made two findings that are likely to impact: (1) the scope…
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