Anti-money laundering compliance in the money services business industry

Fall 2012 benchmarking report

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I am pleased to present our Anti-money laundering compliance in the money services business industry: 2012 benchmarking report. We hope that it will be used to benefit organizations across the money services and financial institutions industry, as we believe it brings forward information that was not easily accessible. We hope this report assists you with understanding today’s compliance benchmark, the goals for tomorrow and in the ongoing fight against money laundering and terrorist financing.

Jennifer Fiddian-Green CA.IFA, CFI, CAMS, CMA, CFEPartnerGrant Thornton LLP

We believe the experience and knowledge we’ve gained over the past few years has placed us in a unique position to offer insight into the status of the industry’s anti-money laundering compliance. This benchmarking report reflects the culmination of public research, as well as the knowledge we’ve gained by completing over 150 anti-money laundering compliance program-related engagements. These were focused particularly on the money services business (MSB) industry as well as others including securities dealers, financial institutions, online transaction processing organizations, trust companies, and government organizations. What’s apparent from our research and experience is that the anti-money laundering compliance programs of money services businesses are now starting to deliver the desired results. However, it is also apparent that many MSBs need to start focusing on the identification of potentially suspicious transactions—perhaps this is simply an evolution of the compliance regime exercise now that the rest of the program elements are in place.

From the practice leader

The anti-money laundering team at Grant Thornton LLP has had the opportunity to work with money services businesses—large, small and everything in between—from all across Canada over the past few years. It has given us great opportunity to meet those who are connected with people, cultures and communities from all over the world. In our experience the money services business industry is highly entrepreneurial, dynamic, diverse and serves the needs of many Canadians and Canadian residents-to-be.

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Contents

Introduction 4 Purpose 4 Methodology 5Profile of the MSB population 6 Types of services offered by the MSBs 6 Geographical regions served by the MSBs 6 Types of clients served by the MSBs 7 Customer interaction types 7 Size of the MSB: number of locations, employees, use of agents 7 Documented contracts with agents 7 Agent monitoring: background due diligence and regular site visits 8 Review of AML compliance program 8Compliance program elements 8 Policies and procedures 8 Compliance officer 9 The risk assessment 9 Training 10 Testing as part of training 10 Recordkeeping 11 Transaction processing system 11 Transaction reporting (large cash and electronic funds transfers) 12 Suspicious transactions 12 Terrorists and designated individuals 13Public notice of administrative monetary penalties 14About Grant Thornton LLP 15

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Introduction

this report can help both MSB and financial institutions by establishing today’s benchmark and tomorrow’s goals for AML compliance programs. Specifically, to assist:• with identifying and evaluating the

prevalence of compliance practices found within the MSB industry;

• in determining the impact that specific practices can have on a compliance program’s effectiveness;

• MSBs with establishing effective compliance practices and to determine the relative standing of their organization within the industry;

• MSBs in managing their relationships with financial institution partners; and

• regulators in understanding the industry’s compliance practices and to evaluate the pace at which changes in the industry are progressing.

“self-banked” in communities across the country. These services are targeted by and vulnerable to money laundering and those wishing to finance terrorism. FINTRAC reports indicate that MSBs are the second most used sector for money laundering and terrorist financing schemes after financial institutions, and that transactions through MSBs represent 36% of all case disclosures made by FINTRAC to law enforcement.2 A rigorous and effective anti-money laundering and terrorist financing deterrence program is a critical success factor for today’s MSB organizations.

Purpose This benchmarking report was created with the goal of providing MSBs and financial institution organizations—both with AML compliance objectives—a critical tool to assist in evaluating the results of an AML compliance program review and any planned program changes. It is our experience that the AML compliance programs of MSB organizations are just now starting to deliver the rigour and effectiveness that serve to protect Canada’s financial systems from abuse by those with illegal funds or criminal intent. We believe that

2 “Money Laundering and Terrorist Financing Trends in FINTRAC Cases Disclosed Between 2007 and 2011,” FINTRAC Typologies and Trends Reports (April 2012): http://www.fintrac.gc.ca/publications/typologies/2012-04-eng.asp

Every year around the world, large amounts of funds are generated from illegal activities including drug trafficking, tax evasion, people smuggling, theft, arms trafficking and corrupt practices. Money laundering—the process of concealing the source of illegally obtained money—plays a crucial role in allowing criminals to continue to perpetrate these crimes. Money laundering and terrorist financing is a global phenomenon, with the estimated amount of money laundered globally in any one year ranging from 2–5% of global GDP, or US$800 billion to US$2 trillion.1

In Canada, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) created the Financial Transaction and Reports Analysis Centre of Canada (FINTRAC), Canada’s financial intelligence unit. Over the past decade, regulated organizations across the country have worked to protect the integrity of Canada’s financial systems by implementing programs to comply with the PCMLTFA and its regulations and by reporting transactions to FINTRAC.

Two popular services offered by money services businesses (MSBs), foreign exchange and money remittance service providers, play a vital role in providing financial services to the “unbanked” and

1 “Money-Laundering and Globalization,” United Nations Office on Drugs and Crime: http://www.unodc.org/unodc/en/money-laundering/globalization.html

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was used to assist with determining the prevalence of specific characteristics and practices. In several areas throughout this benchmarking report we measured the number of MSBs out of the benchmarking population that had deficiencies in specific areas. Deficiencies are defined specifically as items or areas where the MSB’s documentation, process or reporting was not sufficient to meet the requirements of the PCMLTFA and its regulations.

In evaluating the effectiveness of the various MSB compliance program elements, different measures were used to measure different characteristics depending on the available information. For example, the use of an automated versus manual transaction processing system was used to understand the occurrence, or effectiveness of identifying transactions suspicious of money laundering which were then subsequently reported to FINTRAC. Whereas, we reviewed whether or not employee testing as part of an MSB’s training process was effective by comparing this practice against the level of record keeping deficiencies identified.

Methodology The information used within this report is the aggregation of knowledge that the AML team at Grant Thornton has obtained by performing over 150 AML-related engagements, including over 100 different MSB organizations for compliance with the PCMLTFA and regulations. This report also incorporates information obtained from publicly available sources.

The data used to compile this benchmarking report has been reviewed to ensure that the confidentiality of each individual entity is maintained, and that the inclusion of information could not be used to identify an individual business or MSB organization. Only overall summary statistics for the population of data available to us or subset (as appropriate of the population) were used.

In determining the prevalence of a characteristic or practice in the industry we only included information which we assessed as being reasonable to rely on. The same MSB may have been reviewed more than once and only the last instance of review results was used. Furthermore, information from AML reviews as well as risk assessment assistance engagements

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Profile of the MSB population

This section of the report provides background information to help the user understand the profile of the MSBs included in the benchmarking population.

Types of services offered by the MSBsThe majority of MSBs included in the benchmark population provide money remittance services and close to half of the population provide currency exchange services. Other services provided include cheque cashing, money orders, and payday loans. Many of the MSBs provide multiple of these services. This population is fairly reflective of the data reported by FINTRAC3 in Money Laundering and Terrorist Financing (ML/TF) Typologies and Trends for Canadian Money Services Businesses (MSBs) – July 2010 wherein MSBs were reported as predominantly providing money remittance services (75%) and foreign exchange services (70%).

The graph to the right shows the services offered by the MSB benchmarking population (note that many MSBs offer more than one of the listed services).

Geographical regions served by MSBs who provide remittance servicesOf the MSBs that provide money remittance services, we found that while a majority of the MSBs in the population typically serve a specific geographic region, a significant portion (just over a

3 “Money Laundering and Terrorist Financing (ML/TF) Typologies and Trends for Canadian Money Services Businesses (MSBs),” FINTRAC Typologies and Trends Reports (July 2010): http://www.fintrac.gc.ca/publications/typologies/2010-07-eng.asp

quarter of all of the MSBs that provide money remittance services) provide remittance services broadly to regions around the world—either using established global networks or using their own proprietary networks. Half of the MSBs in the benchmark population, who provided remittance services, served or delivered funds to and from Asian countries. When we looked at the remittance networks that were being used, we found that more than half of all MSBs used only a proprietary network (57%), with the remainder being divided between those using only an established global network (25%), or both (18%).

SERVICES OFFERED BY THE MSBS INCLUDED IN THE BENCHMARKING POPULATION PERCENTAGE OF MSBS OFFERING

70%

60%

50%

40%

30%

20%

10%

0%

Money remittance services-regions served by the MSBs

Remittance networks

Asia50%

Europe1%

Africa 8%

Non-specific26%

Middle East 5%

South America 10%

Both18%

Proprietary57%

Established global network 25%

Remittance Foreign exchange

Remittance as an agent

Cheque cashing

Money order Payday loans

TYPE OF SERVICE

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Number of locations of the MSBs in the benchmarking population

Documented contracts with agents A documented contract between an MSB and its agent(s) can clearly lay out the duties and obligations of each of the parties and allow for an orderly means of settling any disputes that may arise. Over half (53%) of the MSB benchmark population did not have documented contracts in place with their active agents, indicating that this is a business area requiring attention.

Put in place documented contracts which clearly lay out compliance program obligations and provide right of audit to protect your organization. Up front background due diligence and regular site visits to test compliance will protect your organization over the longer term.

Customer interaction

Multiple access50%

Face-to-faceonly48%

Online only2%

Size of the MSB: number of locations, employees, use of agentsWhile the MSB industry in Canada is dominated by a handful of larger businesses, there are also numerous smaller MSBs ranging in size from one location to larger organizations with hundreds of locations in Canada and also abroad. Location has been defined for purposes of this benchmarking report to include branch and agent locations. Agents are individuals or entities that are not directly employed by the MSB, but are authorized to act on behalf of the MSB to provide money services to clients. Of the MSB benchmark population, 24% provided services to clients using agents. A number of the MSBs in the benchmark population had less than five employees, including owner operated, family-run businesses.

Number of employees of the MSBs in the benchmarking population

Types of clients served by the MSBsClients serviced by the MSBs include corporate or other types of entities, individuals or a combination of both. Corporate clients typically served include institutions or businesses who seek the services of the MSB to assist them with making payments to foreign vendors. These transactions are usually for larger dollar amounts. Individual clients are generally seeking the services of the MSB to perform smaller currency exchange transactions, for the remittance of money to family members overseas or personal travel.The graph below shows the proportion of MSBs that have corporate clients, individual clients, or both. While the majority of MSBs served both, some MSBs have carved out a niche for themselves by serving a targeted market, many of these involving a specific ethnic community.

Types of clients served by the MSBs included in the benchmarking population

Customer interaction typesThe MSB benchmarking population was analyzed to understand how the MSBs interacted with their customers. The percentage of MSBs providing online access to customers was only 2%, while 48% interacted in person/face-to-face access and 50% provided multiple forms of access. For those organizations providing multiple interaction types, these were usually only provided after an initial face-to-face meeting.

Individuals36%

Both62%

Corporations2%

More than 2517%

Five or fewer employees60%

Six to 1015%

11 to 258%

More than 256%

One location65%

Six to 2510%

Five or fewer 19%

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Compliance program elements

The most common policy and procedure deficiencies included: • insufficient detail of recordkeeping

responsibilities (e.g., requirement to document beneficial ownership of corporate customers);

• no documentation of when and how to make third-party determinations;

• no definitions of third-party and/or PEFP provided;

• no documentation that the manual/policies and procedures had been reviewed and authorized by senior management; and

• no documentation of the responsibilities of the compliance officer.

Policy and procedure deficiencies

Agent monitoring: background due diligence and regular site visitsLess than half of the MSBs included in the benchmarking population (only 38%) conducted background due diligence when first deciding to take on a new agent. Further, only 37% of the MSBs perform regular site visits of their agents. Site visits usually included some testing, inspection and inquiry of how regulatory requirements were being adhered to. It was not necessarily the same group of MSBs who performed both of these procedures, only approximately half of the MSBs who conducted due diligence also performed regular agent site visits.

Review of AML compliance programThe MSB benchmarking population was analyzed to understand the percentage of MSBs whose compliance program had been subject to a prior review(s), whether this was performed by Grant Thornton or another party. Approximately 28% of the benchmarking population had been subject to more than one compliance program review.

For those MSBs who had more than one review of their program completed, there was a marked decrease in documentation deficiencies (risk assessments and policy and procedures), however, there still continued to be record keeping and reporting deficiencies.

Policies and proceduresA required element of an MSB’s compliance program is to have documented compliance policies and procedures. The majority of the benchmarking population (66% of the MSBs) had deficiencies identified in their program reviews. The remaining MSBs with no identified deficiencies were likely to have more than five employees, developed their policies and procedures using external resources and a compliance officer that had received external training.

Deficiencies66%

No deficiency34%

Referrals are not enough.Background due diligence results can be known within days. Focused investigative research can identify serious issues or concerns you need to know about. Make sure you get the facts about the people you do business with—the potential cost of failing to identify problems can be prohibitively high.

Make sure that your policies and procedures reflect and align with your money service business activities. Also ensure this is true for your risk assessment as well. If your risk assessment includes controls to mitigate risk, these controls need to be performed.

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The risk assessmentA good risk assessment documents specific money laundering and terrorist financing risks specific to that individual business and includes mitigating controls. This is a required element of the AML compliance program regime for an MSB and it can also be a roadmap to assist others with understanding the business, the risks associated with the money service transactions facilitated, the customers and geographic regions serviced. While most (94.5%) of the MSBs in the benchmarking population had a documented risk assessment, the majority were still in the process of making the risk assessment a practical reality of their business operations. An effectively implemented risk assessment fundamentally affects how an MSB conducts their business.

Only a small number of the MSBs had compliance officers who were certified with relevant AML credentials (e.g. a certified anti-money laundering specialist designation). We expect that going forward more organizations will require this expertise and qualification of their compliance officers.

Of the MSBs in the benchmarking population, 23% had a compliance officer that was supported by a team providing assistance to oversee and meet the compliance program requirements. We noted that for those MSBs with a compliance officer supported by a team, the rates of record keeping and reporting deficiencies were higher. This indicates that while these teams are monitoring and processing a higher volume of transactions, on-going management of the compliance program team is essential to ensure effectiveness of results.

Compliance officerEach MSB is required to designate a compliance officer (CO) responsible for its AML compliance program. The data available in the benchmarking population was analysed to try and understand who was fulfilling the role and if and how this person was supported. In the benchmarking population, 45% of the MSBs had the owner of the organization fulfilling the compliance officer role. In general, these MSBs were identified as smaller and more likely to have policies and procedures with identified deficiencies. For these MSBs, it was also more likely that the owner, for their compliance officer role, received external training. There was no marked difference regarding record keeping or reporting deficiencies for MSBs that had the owner as the compliance officer versus MSBs which had another individual fulfilling that role.

The CO role requires expertise and experience, and needs to be taken seriously. In July 2012, HSBC’s chief compliance officer resigned from the role amidst allegations that the bank had inadvertently allowed the laundering of Mexican drug cartel money.

The risk assessment really needs to be the foundation of your AML program. Document your higher risks and ensure you are actively monitoring for these higher risk customers and transactions. Once identified, protect yourself and your business by executing on your documented controls such as obtaining source of funds information before you take on responsibility for facilitating the transaction.

Note: This bar chart provides detail data results for the pie chart on the previous page.

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Testing as part of trainingTesting reinforces learning. It also helps the MSB determine whether its training efforts have been effective, and provides additional motivation for staff. In the benchmarking population, 24% of MSBs use testing as part of their staff training program, and 76% do not use any form of documented testing. The MSBs that used testing in their program were less likely to have record keeping deficiencies and were more likely to operate from one location. However, the testing of staff as part of an MSB training program, did not have any marked impact on whether or not an MSB was reporting STRs. We expect this will change as training evolves to focus more on how to identify suspicious transactions, with less focus on general awareness and the recordkeeping requirements. We do believe the data reflects that testing works—while MSBs with testing did have recordkeeping deficiencies the rate of deficiency were comparatively lower.

The benchmarking population indicates that most (84%) of the MSBs did not have any high-risk areas identified in their risk assessment. Of the MSBs that did identify high risks (16%) these businesses were much more likely to have had their documentation developed externally and to train their compliance officer externally. However, it is interesting to note that these same MSBs were less likely to file a suspicious transaction report (STR). This is reviewed in more detail later in this report.

TrainingDocumented ongoing training of the compliance program requirements must be maintained. We looked at how the compliance officers of MSBs received and maintained their training and we looked at how the training for others in the organization was delivered and maintained. In the MSB benchmarking population, the compliance officers were primarily obtaining their training by accessing internal resources or visiting and using the resources on the FINTRAC website. This group accounted for 65% of the compliance officers for which data was available. The remaining 35% of compliance officers were receiving external training.

There was no marked difference regarding recordkeeping or reporting deficiencies between compliance officers trained internally or externally. However, the externally trained officers did have fewer identified deficiencies regarding policy and procedure documentation and risk assessments. It is essential to remember that good training is only one element of your compliance program, and that all of the compliance program elements need to be in place and working, including the monitoring for and reporting of suspicious transactions.

Training programs for staff may be developed internally or externally, or in combination. In the benchmarking population, the majority (71%) of MSBs used internal resources exclusively to train staff, 7% used external resources exclusively and 22% used a combination of programs. MSBs using internal resources to train staff tended to have lower rates of recordkeeping and reporting deficiencies (albeit rates of deficiency were still high).

Type of training

External 7%

Both22%

Internal 71%

There are now MSB industry-tailored training resources available which organizations can access online and can also use to track employee completion and test results.

Testing doesn’t only reinforce learning, it helps the MSB understand the level of knowledge that its staff has. It also demonstrates a commitment to AML and it locks in your training investment.

Training should include materials that are relevant to the employee’s role within the organization, and should provide an understanding of AML as well as specific knowledge necessary for that person to perform their part of the MSB’s AML strategy. Don’t provide blanket training.

Train and review your specific recordkeeping requirements with staff. Use examples specific to your organization to make it effective.

Transaction processing systemTransaction processing system refers to the manner in which a customer transaction is recorded. An automated transaction system refers to a system where the customer’s information, as well as the transaction information is electronically recorded and then processed. A manual system refers to a process for which both the customer and transaction information is first recorded manually (on paper). Information from a manual system is kept in paper format or it may be entered into a spreadsheet. In the benchmarking population, 54% of MSBs used automated transaction systems while 46% of MSBs used a manual system. The MSBs that used automated transaction systems usually had more locations and processed a higher volume of customer transactions. Automated systems also resulted in a higher likelihood of the MSB filing an STR report with FINTRAC. The rates of recordkeeping deficiencies were high regardless of whether the MSB was using an automated or manual transaction processing system.

individuals authorized to transact for the corporation were not collected or recorded; and

• for third-party and PEPF determinations no documentation that enquiries were made with client.

Testing in training

RecordkeepingIn the benchmarking population, 76% of the MSBs had recordkeeping deficiencies. Given the high rate of deficiency, we looked in detail at the percentage of records that had record keeping deficiencies for each MSB, we then averaged and summarized this. Out of all of the records reviewed, across all of the MSBs in the benchmarking population, an average of 27% of the records tested contained deficiencies. We were able to identify two program elements which had a positive impact on record keeping (meaning that MSBs with these program elements had a lower rate of record keeping deficiency). These elements were the use of an automated system to process transactions and the use of testing as part of staff training.

The more typical recordkeeping deficiencies were:• staff was unclear as to what the

specific recordkeeping requirements were (i.e., were not obtaining address, telephone, date of birth information from clients);

• occupation information was either not obtained or what was documented was unclear (e.g., self-employed, manager, owner);

• corporate beneficial ownership information was not obtained or documented, also details of the

Use of testing24%

No testing76%

Occupation—this is really all about trying to understand the source of a person’s funds, how they earn their money. Documenting that someone is a manager doesn’t provide any information as to source of funds. Be specific and detailed.

Don’t make assumptions for your clients. When required, third party and politically exposed foreign persons enquiries need to be made and documented. Also, for larger transactions, ones out of pattern or not expected for a client, enquire and document as to source of funds, don’t assume it.

Note: This bar chart provides detail data results for the pie chart to the left.

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Suspicious transactionsMost MSBs (73%) did not file any STRs with FINTRAC over the time period reviewed which was generally a three month to one year timeframe. The data indicates that it was typically larger MSBs that filed STRs and that these organizations were more likely to use an automated transaction system, meaning the organization likely had automated monitoring procedures. As well, MSBs that filed STRs were more likely to have delivered their training using internal resources and to have developed their policies and procedures internally.

Transaction processing system

Transaction reporting (large cash and electronic funds transfers)In the benchmarking population, 66% had large cash and/or electronic funds transfers reporting deficiencies. Given the high rate of deficiency, we looked in detail at the percentage of transaction reports that had reporting deficiencies for each MSB, we then averaged and summarized this. Out of all of the reports reviewed, 33.4% of LCT reports and 38.5% of EFT reports had deficiencies.

The most common deficiencies were:• late filings (most common); • reportable transaction not identified

by the MSB until the completion of the review (this was most common for transactions meeting the 24-hour rule threshold); and

• filing incorrect information.

Have notfiled STRs73%

Filed STRs27%

Automated54%

Manual46%

Even smaller MSBs that record their transactions manually can benefit from the low-cost solution of recording transactions on a spreadsheet. This will help to identify anything suspicious and also demonstrate to others that you have the ability to adequately monitor your transactions.

Ensuring that the 24-hour reporting rule requirement is met can be tricky for MSBs that process a high volume of transactions using a manual system. It will be harder and harder to justify maintaining manual records. Before you make the system investment, even the use of a simple spreadsheet can assist with ensuring the requirements are met.

Note: This bar chart provides detail data results for the pie chart above.

MSBs that filed STRs

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Terrorist and designated individuals detection system

Automated detection system with deficiencies

Terrorists and designated individualsWe analyzed the data available to identify how many MSBs were using an automated system to check customer names against available listings of sanctioned individuals and entities. Results showed that 57% of MSBs were manually checking customer names, and 43% had an automated process to do this for them. Most MSB organizations which were manually checking were doing so against the OSFI list only, whereas when an automated process was used to do the checking, usually multiple lists were checked, including at least the OSFI and OFAC lists.

We determined that for the MSBs using an automated system, during the time of their compliance program review, 45% of these MSBs had identified deficiencies.

Deficiencies were specifically related to:• the list the system was using to check

names against was not the most updated, and in some cases was several months outdated; and

• technical issues with the system such that the comparison process was simply not working as it was supposed to.

We identified that most of the MSBs in the benchmarking population had transactions which the MSB needed to review in order to determine whether or not any STR filing was required. At the time of the review these MSBs had not documented any form of previous monitoring of these transactions. The most commonly identified types of transactions were:• numerous transactions made by the

same customer over shorter time periods (e.g., one to ten days); and

• larger transactions conducted by customers and source of funds information was unknown or what was known/documented was not clear/did not make sense.

It’s critical that all staff (front counter, back office/ processing, and management) are properly trained and aware of how to recognize the red flags of an unusual transaction—one suspicious of money laundering or terrorist financing. Training is now expected to be tailored to the role and position of your staff.

MSBs which are not identifying and reporting suspicious transactions to FINTRAC need to really stand back and assess their risk, identification and monitoring processes. Is their compliance program really effective? Today the expectation is that within this industry an effective program will identify suspicious transactions. If you are not reporting, you need to be able to prove that you don’t have to.

Automated43%

Manual57%

No deficiency55%

Deficiencyidentified45%

Understanding source of funds: A bank account is where the money last comes from before it comes to your organization; knowing this is not enough. Find out how the money came to be owned and in the control of your potential customer.

Transactions need to be monitored for unusual, potentially suspicious activity. Make sure this process is documented.

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Public notice of administrative monetary penalties

Posted on FINTRAC’s website are persons and entities that have been issued a monetary penalty where a “serious or very serious” violation was committed (15 MSBs in total).4 The chart to the right summarizes the types of penalties cited and provides comparison information on the rate of occurrence across the MSBs who were issued penalties. We note the higher number of penalties regarding compliance program documentation versus the number of penalties regarding the substantive results of a compliance program, for example, the identification and reporting of STRs.

4 As of September 1, 2012

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We have made efforts to ensure information in this article is accurate as of its original publication date, being September 2012, however, we make no representations as to its current accuracy. In addition, information or views expressed herein are provided on an informational basis only and should not be taken as official statements of position, or be considered technical advice. For more information about the topics expressed herein, please contact a Grant Thornton adviser in your area who will be happy to answer your questions.

Grant Thornton is one of the world’s leading organizations of independent assurance, tax and advisory firms. These firms help dynamic organizations unlock their potential for growth by providing meaningful, actionable advice through a broad range of services. Proactive teams, led by approachable partners in these firms, use insights, experience and instinct to solve complex issues for privately owned, publicly listed and public sector clients. Over 31,000 Grant Thornton people, across 100 countries, are focused on making a difference to clients, colleagues and the communities in which we live and work.

About Grant Thornton in CanadaGrant Thornton LLP is a leading Canadian accounting and advisory firm providing audit, tax and advisory services to private and public organizations. Together with the Quebec firm Raymond Chabot Grant Thornton LLP, Grant Thornton in Canada has approximately 4,000 people in offices across Canada. Grant Thornton LLP is a Canadian member of Grant Thornton International Ltd, whose member firms operate in close to 100 countries worldwide.

Our national anti-money laundering team: Jennifer Fiddian-Green, Patrick Ho, Michelle Sarmiento, Dave Chu (Toronto); Pat McParland, Albina Alimerko (Vancouver); Al Bleau (Calgary)Corey-Anne Bloom (Montreal)

Toll-free line and email to directly contact our national AML team:T +1 855 747 2647E msb@ca.gt.com

About Grant Thornton LLP