The Proceeds of Crime (Money Laundering) and Terrorist Financing Act compels all industry participants to implement a comprehensive compliance regime and maintain necessary rigor. As well, FINTRAC Guideline 4 prescribes periodic reviews to ensure the effectiveness of compliance policies and procedures. The key challenge for many financial institutions is to sustain their effectiveness on an ongoing basis.

ARRAY Development has developed an Anti-Money Laundering (AML) Accountability Review Package in response to requests from our executive clients concerned with their organizations' ongoing preparedness in addressing the requirements of the Act. Our AML Accountability Review Package provides for meaningful feedback to financial services companies on the effectiveness of their programs, thus helping to avoid the severe consequences of non-compliance. An AML Accountability Review addresses issues related to corporate risk management and the legal liability of corporate directors, officers, supervisors and staff in managing the reporting cycle for suspicious transactions. Our review identifies action areas that can have immediate impact on your effectiveness. Delivered by leading financial services consultants, we offer this comprehensive review service at a highly competitive price.

FINTRAC Guideline 4: Implementation of a Compliance Regime (November 2003) prescribes periodic reviews of compliance policies and procedures by all financial entities, to test their effectiveness. Section 4.3 Review of the Compliance Policies and Procedures specifies that the review is to be conducted by an internal or external auditor. A typical review could include interviews, tests and samplings, such as:

• Interviews with those handling transactions and with their supervisors to determine their knowledge of the legislative requirements and corporate policies and procedures.

• A review of the criteria and process for identifying and reporting suspicious transactions.

• A sampling of large cash transactions followed by a review of their reporting.

• A sampling of international electronic funds transfers, if applicable, followed by a review of the reporting of such transactions.

• A test of the validity and reasonableness of any exceptions to large cash transaction reports, if applicable, including the required annual report to FINTRAC.

• A test of the record-keeping system for compliance with the legislation.

• A test of the client identification procedures for compliance with the legislation.

The scope and details of the review depend on the nature, size and complexity of corporate operations. The review process should be well documented, identifying weaknesses in policies and procedures. All deficiencies should be identified and reported to senior management or the board of directors. The report should include a request for a response indicating corrective measures and a timeline for implementing follow-up actions.

ARRAY Development and its Toronto affiliate Value Improvement Associates have excellent track records in helping leading financial institutions and government agencies to conceptualize, prototype and develop highly interactive and intelligent business solutions across the financial services industry. Our objective is to support you in making your business processes efficient, cost-effective and secure. Our partnership focuses on four key areas of value improvement for our clients: corporate governance and management, revenue improvement, strategic cost management and risk management. We bring tier one consulting experience, global industry expertise and offer our services at a highly competitive price.

Gerry Purcell, Head of ARRAY Developments Financial Consulting Practice and Managing Director of Toronto-based Value Improvement Associates has over 20 years of global experience, both as an executive and management consultant. Gerry and his associates have a track record as agents for change and have a collaborative approach that successfully addresses complex business issues and optimizes results. Our service model is simple: combine practical experience and tier one capability; leverage robust industry knowledge; provide high value advice and tangible results without the overhead of large consulting organizations.

Our consultants have worked for a number of large and small financial institutions, as well as with government and supplier organizations:

• ABN AMRO/Banco Real
• Bank of Canada
• Bank of Montreal
• Bell Canada
• BMO Nesbitt Burns
• Caisse depot et placement du Quebec
• Canada Investment and Savings
• Canada Post Corporation
• Canadian Revenue Agency
• CIBC
• Citibank
• IBM
• National Bank of Canada
• Nortel Networks
• Public Works and Government Services Canada
• ScotiaBank
• Treasury Board of Canada
• University Bank
• Whitney National Bank