Director's briefing binder - November 2020

On this page

1. Introduction and Background
   • FINTRAC Overview
   • Mandate and Key Partners
   • FINTRAC Strategic Plan 2019-24
   • PCMLTFA Overview
   • Pandemic Response
2. Overviews
   • FINTRAC Financial Overview
   • Executive Office Financial Overview
   • Legal Services Overview
   • Compliance Overview
   • Intelligence Overview
   • Enterprise Policy, Research and Programs Overview
   • People and Culture Overview
   • Information Management and Information Technology Overview
3. Key Issues and Files
   • Commission of Inquiry into Money Laundering in British Columbia (Cullen Commission)
   • Business Information and Analytics System
   • Budget 2020 and July Economic and Fiscal Update
   • HQ on the Move
   • Regulatory Amendments

A. Introduction and Background

Overview

Welcome to FINTRAC!

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada's Financial Intelligence Unit. The Centre's mandate is to facilitate the detection, prevention and deterrence of money laundering and the financing of terrorist activities, while ensuring the protection of personal information under its control.

FINTRAC's Core Functions are to:

• Receive reports and information from reporting entities;
• Analyze and assess the reports and information received from reporting entities and disclose designated information to police, national security agencies, tax, border and immigration authorities, and provincial securities commissions;
• Ensure that the reporting entities comply with the obligations defined in Parts 1 and 1.1 of the Proceeds of Crime Money Laundering and Terrorist Financing Act (PCMLTFA);
• Administer the Money Services Businesses Registry, as per the PCMLTFA;
• Protect the personal information received under the Act; and
• Inform the public about trends in money laundering and the financing of terrorist activities.

Who We Are

FINTRAC:

• Canada's Financial Intelligence Unit (FIU) and Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) regulator.
• An independent agency that reports to the Minister of Finance.
• Created in 2000; its enabling act is the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
• FINTRAC HQ is currently located at 234 Laurier W., [REDACTED]. FINTRAC has also three regional offices in Montréal, Toronto and Vancouver.
• As of March 31, 2020, the headcount is at 371 employees.
• The current 2020-21 salary and O&M budget is $53.4 million excluding employee benefits program (EBP). Including all pending sources of funds, the projected budget for 2020-21 increases to $74.3 million excluding EBP.
• Received over 30 million financial transaction reports in 2019-20.
• Has the unique ability to track fund movements.
• Can disclose financial intelligence only if it is relevant to money laundering, terrorist activity financing, or threats to the security of Canada as defined in the CSIS Act.
• Has no investigative/enforcement authority.

FINTRAC Organizational Chart

The Financial Intelligence Program

FINTRAC produces actionable financial intelligence, including disclosures that assist Canada's police, law enforcement, national security and other partner agencies in combatting money laundering, terrorism financing and threats to the security of Canada.The financial intelligence disclosed by FINTRAC is used in a wide variety of criminal investigations related to the funding of terrorist activities and the laundering of proceeds originating from crimes such as drug trafficking, fraud, tax evasion, corruption and human trafficking, to name a few.

FINTRAC describes its intelligence as "actionable" since it can show links between individuals and businesses that may have been previously unknown to investigators. Financial intelligence enables police, law enforcement and national security agencies to refine the scope of their investigations, to shift their sights to different targets and to identify assets for seizure and forfeiture. FINTRAC also produces strategic financial intelligence for federal policy and decision-makers, reporting entities across the country, international partners and other stakeholders.

The Compliance Program

The PCMLTFA establishes obligations for reporting entities to develop a compliance regime in order to identify clients, monitor business relationships, keep records and report certain types of financial transactions. FINTRAC undertakes enabling and enforcement actions to ensure that the reporting entities operating within Canada's financial system fulfill their PCMLTFA obligations. FINTRAC also maintains a registry of money services businesses in Canada.

FINTRAC's Vision

• Safe Canadians, Secure Economy: Contributing to the safety of Canadians and the security of the economy, as a trusted leader in the global fight against money laundering and terrorist activity financing.

FINTRAC's Governance

The governance bodies of FINTRAC provide an integrated corporate system of decision-making that enables (1) effective allocation of resources to priorities; (2) alignment of activities to outcomes; and (3) management of accountabilities.

Executive Committee (EXCO)

The Executive Committee (EXCO) provides strategic vision and direction, establishes strategic priorities, provides oversight and guidance on programs and horizontal activities, and ensures the essential conditions—internal coherence, corporate discipline and accountabilities —are in place to deliver effective results.

Scope of activities:

• Establishes the vision, strategic priorities, strategic policy, program and corporate management frameworks for the Centre's operations.
• Makes informed proactive and timely decisions to achieve results and alignment with priorities.
• Ensures sound stewardship of the Centre's resources.
• Reviews and evaluates program results, including its audit and evaluation program, and directs corrective actions.
• Ensures that corporate planning aligns corporate priorities, sector business plans and resource allocations.
• Ensures the external delivery and integrity of program activities.
• Reviews and approves domestic and international strategic engagement and relationship management activities and key messaging.
• Reviews nominations and selects recipients of enterprise-wide awards and recognitions.
• As a separate employer, ensures the overall compensation program is sound, reviews employee performance results and makes decision on performance compensation.

Membership:

Chair: Director of FINTRAC

Standing Members include the General Counsel and all direct repots to the Director.

Ex-officio includes the Chair of the Management Advisory Committee who may attend when and if needed to clarify MAC discussions.

Management Advisory Committee (MAC)

The Management Advisory Committee (MAC) supports the EXCO in fulfilling its mandate by providing strategic advice and recommendations on issues, risks and opportunities for the sound management of programs, policies, processes and systems that sustains FINTRAC's business operations, as well as for key investments, priorities and policy development initiatives to advance FINTRAC's change agenda.

Scope of activities:

• Anticipates issues and provides advice and guidance on issues raised, offering options to support recommendations and/or key information provided to EXCO.
• Provides oversight on the operational and strategic plans and priorities to ensure continuous progression and achievement of results.
• Serves as a forum for the review, discussion and challenge of FINTRAC's program and corporate policies and procedures with a focus on proposed changes that have broader impacts on the Centre.
• Recommends policy priorities to guide program delivery and ensures program policy proposals reflect FINTRAC and government priorities.
• Executes a decision-making function on some administrative files, raising issues of that nature as required.
• Ensures that initiatives related to internal services are compliant with Government of Canada policies, directives and practices.
• Makes recommendations on the management of our People, including serving as a FINTRAC Exchange Program Board.
• Makes recommendations on the management of the Centre's financial, asset, real property and IM/IT resources and allocation based on strategic plans and priorities.
• Approves investment project gating/decisions on those investment projects approved by EXCO through the annual integrated planning process.
• Provides a consultation forum on corporate planning and reporting documents.

Membership:

Senior Managers representing each of FINTRAC's sectors

Sub-Committees:

The following four sub-committees support MAC by providing advice and recommendations on the achievement of results and evolution of key business areas:

Culture and Change Management Sub-Committee enables FINTRAC to deliver a consistent and effective change strategy across the Centre to drive, support and maintain a healthy and effective workplace, and a skilled and engaged workforce equipped with the tools and resources needed to successfully deliver current and future programs and services.In doing so, this sub-committee recommends priorities, strategies, areas for investments, and areas for evaluation to continue to strengthen a higher performing culture founded on our values, ethics and wellness.

Digital Innovation Sub-Committee enables FINTRAC to maximize business performance by orchestrating the transformation of our digital environment that is adaptive to ongoing change.In doing so, this sub-committee explores, analyses and recommends areas of priority research and investments that will strengthen our ability to advance data management opportunities and the user and client technology experience.

Intelligence Sub-Committee examines the overall effectiveness of one of FINTRAC's Core Responsibility – Production and Dissemination of Financial Intelligence – and enable FINTRAC to effectively assess and prioritize the intelligence community priorities.In doing so, this sub-committee recommends financial intelligence priorities, assesses and recommends participation at interdepartmental intelligence-related committees and develop associated key messages, recommends priority outreach activities and develops associated key messages, and recommends participation in public private partnerships initiatives, areas for investments and areas for evaluation to determine the effectiveness of FINTRAC's financial intelligence program.

Policy and Planning Sub-Committee influences FINTRAC's policy and planning agenda for the long-term.In doing so, informed by operational experience and intelligence assessments, this sub-committee considers medium (2-4 years) and long-term (5-10 years) policy, legislative and regulatory enhancement opportunities, and recommends strategies and priorities that will help position the Centre for the future, both domestically and internationally.

Money Laundering vs. Terrorist Activity Financing

What is money laundering?

Money laundering is the process used to disguise the source of money or assets derived from criminal activity. There are three recognized stages in the money laundering process:

1. Placement, which involves placing the proceeds of crime in the financial system;
2. Layering, which involves converting the proceeds of crime into another form and creating complex layers of financial transactions to disguise the audit trail, the source and ownership of funds. This stage may involve transactions such as the buying and selling of stocks, commodities or property; and
3. Integration, which involves placing the laundered proceeds back into the economy to create the perception of legitimacy.

The money laundering process is continuous, with new "dirty" money constantly being introduced into the financial system.

What is terrorist activity financing?

Terrorist activity financing is the use of funds, property or other services to encourage, plan, assist or engage in acts of terrorism, where the primary motivation is not financial gain.

There are two main differences that distinguish terrorist activity financing from money laundering:

1. Funds can be from legitimate sources, not just criminal acts; and
2. Money is the means, not the end —the goal is to use funds to facilitate or conduct terrorist activities.

What We Do

FINTRAC has two key functions:

• Ensuring compliance with the PCMLTFA:
  1. Ensure reporting entities comply with their legal obligations;
  2. Receive financial transaction reports from reporting entities; and
  3. Provide feedback and guidance.
• Producing and disseminating financial intelligence:
  1. Analyze information and disclose it to appropriate authorities; and
  2. Develop strategic-level products on trends, patterns, threat actors, vulnerabilities, etc.

Sources of Information for FINTRAC Analysis

Reporting Entities

• Suspicious Transaction Reports (STRs) or Suspicious Attempted Transaction Reports (SATRs)
• International Electronic Funds Transfer Reports (EFTRs) of $10,000 or more
• Large Cash Transaction Reports (LCTRs) of $10,000 or more
• Casino Disbursement Reports (CDRs)
• Terrorist Property Reports (TPRs)

Canada Border Services Agency (CBSA)

• Cross-Border Currency Reports (CBCRs)
• Cross-Border Currency Seizure Reports (CBSRs)

Law enforcement, intelligence agencies, and the general public

• Voluntary Information Records (VIRs)

Foreign financial intelligence units (FIUs)

• Queries (FIUQs) and disclosures

Databases

• Law enforcement and security databases

Publicly available information

• Open source information including information from commercially available databases

FINTRAC's Mandate, Role, and Key Partners

Mandate

FINTRAC's mandate is to assist in the detection, deterrence, and prevention of money laundering and terrorist activity financing and to assist the Minister in carrying out his powers and duties under Part 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) by:

• Receiving the following reports: Suspicious Transactions Reports (STRs), Large Cash Transactions Reports (LCTRs), Electronic Funds Transfer Reports (EFTRs), Terrorist Property Reports (TPRs) and Casino Disbursements Reports (CDRs);
• Receiving reports from the Canada Border Services Agency (CBSA) on the cross-border movement or seizure of currency or monetary instruments valued at $10,000 or more;
• Collecting information that FINTRAC considers relevant to money laundering (ML) or terrorist financing (TF) that is publicly available or stored in certain governmental databases;
• Researching and analyzing data from a variety of information sources that shed light on trends and patterns in ML/TF;
• Analyzing and assessing the reports and information it receives;
• Providing police with financial intelligence that would be relevant to investigating or prosecuting ML and/or TF offences and to providing CSIS with financial intelligence that would be relevant to the threats to the security of Canada;
• Providing financial intelligence to other agencies, if two threshold tests are met;
• Providing foreign Financial Intelligence Units (FIUs), with which there is a Memorandum of Understanding, with financial intelligence that would be relevant to investigating or prosecuting an offence that is substantially similar to a ML or TF offence;
• Ensuring that personal information under its control is protected from unauthorized disclosure;
• Ensuring compliance by the entities subject to the PCMLTFA (reporting entities) with their obligations under the Act and its accompanying regulations;
• Maintaining a registry of money services businesses in Canada;
• Issuing administrative monetary penalties (AMPs) to reporting entities that are in non-compliance with the Act and its accompanying regulations; and,
• Enhancing public awareness and understanding of matters related to ML/TF.

History

Canada's anti-money laundering regime and FINTRAC's origins are rooted in the global effort to combat organized crime and money laundering. The need for international cooperation was reflected in the 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (Vienna Convention), and the 1989 establishment of the Financial Action Task Force (FATF) to combat money laundering.

In 2000, Parliament passed the Proceeds of Crime (Money Laundering) Act requiring the mandatory reporting of suspicious financial transactions and prescribed transactions of the cross-border movement or seizure of currency or monetary instruments valued at $10,000 or more; and creating FINTRAC as the nation's financial intelligence unit. FINTRAC began receiving STRs and voluntary information in the Fall of 2001.

A few months after the attacks of September 11, 2001, Parliament adopted the Anti-Terrorism Act (ATA). As a consequence, FINTRAC's governing legislation was renamed the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and the Centre's mandate was expanded to include the detection and deterrence of terrorist activity financing. At the same time, FINTRAC was given the mandate to make disclosures of financial intelligence to CSIS when the information would be relevant to threats to the security of Canada. These changes were consistent with actions of other governments and organizations, as for instance, the FATF also added terrorist activity financing to its mandate.

In 2006, An Act to amend the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and the Income Tax Act amended the PCMLTFA and expanded the coverage of the Act to new entities and professions and strengthened its deterrence provisions by adding an administrative monetary penalties regime, by expanding the range of information that FINTRAC discloses and by requiring money services businesses (MSBs) to register with FINTRAC. Since then, Canada has made regular amendments to the PCMLTFA, through mechanisms such as the 5-year statutory Parliamentary Review and through Budget Implementation Acts.

FINTRAC's Role in the Larger AML/ATF Effort

Canada's Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) Regime is a horizontal initiative comprising 13 federal partners, both funded and non-funded. The Regime consists of the activities of all partners as well as provincial/regional/municipal regulatory and law enforcement bodies, and private sector entities with obligations under the Act and its regulations.

FINTRAC is a key component of the Regime, responsible for financial intelligence and ensuring compliance with the PCMLTFA and is the only organization created by the PCMLTFA. The Centre maintains strong intelligence sharing relationships with Canadian police services, as well as with the Canadian Security and Intelligence Service (CSIS), the Canada Revenue Agency (CRA), the Canada Border Services Agency (CBSA), the Communications Security Establishment (CSE), the Department of National Defence and the Canadian Forces, and provincial securities regulators, all of which are authorized to receive disclosures of financial intelligence.

FINTRAC also maintains operational and policy linkages with the Department of Finance (which is the policy lead for the national initiative), as well as with Public Safety Canada, the Department of Justice, Global Affairs Canada (GAC) and the Office of the Superintendent of Financial Institutions (OSFI).

On the international front, FINTRAC is part of an expanding global community of financial intelligence units (FIUs) united in the international fight against ML and TF. FINTRAC participates actively in the FATF and the Egmont Group of Financial Intelligence Units, as well as cooperates with a number of international organizations that contribute to enhancing the global effort to combat ML and TF. To date, FINTRAC has signed MOUs with 110 foreign FIUs to exchange financial intelligence related to ML/TF and three MOUs to exchange information related to AML/ATF compliance supervision.

FINTRAC's Partners and Stakeholders:

Reporting Entity (RE) Sectors that Report to FINTRAC

• Financial entities (Banks, credit unions, etc.)
• Life insurance
• Securities Dealers
• Money services businesses (MSBs)
• British Colombia Notaries
• Accountants
• Real estate (brokers, sales representatives and developers)
• Dealers in precious metals and stones
• Casinos
• Agents of the Crown

* The general public can submit voluntary information regarding suspicions of ML or TF

Government Partners

AML/ATF Regime

• Department of Finance
• Canada Border Services Agency
• Canada Revenue Agency
• Canadian Security Intelligence Service
• Department of Justice Canada
• Public Prosecution Service of Canada
• Royal Canadian Mounted Police
• Office of the Superintendent of Financial Institutions
• Global Affairs Canada
• Public Services and Procurement Canada
• Public Safety Canada
• Innovation, Science and Economic Development Canada

Other Government Partners

• Office of the Privacy Commissioner
• Privy Council Office
• Communications Security Establishment
• Department of National Defense and Canadian Armed Forces
• Provincial and municipal police forces
• Provincial/territorial securities regulators

International Partners

• Foreign financial intelligence units with which the Centre has an MOU (110)
• Five Eyes FIUs and other partners (e.g. AML/CFT supervisory agencies)
• Financial Action Task Force (FATF)
• Regional FATF style organizations (e.g. CFATF, APG)
• Egmont Group of Financial Intelligence Units
• World Bank
• International Monetary Fund
• Group of Seven (G7)

Strategic Plan 2019–24

Vision

Safe Canadians, Secure Economy: Contributing to the safety of Canadians and the security of the economy, as a trusted leader in the global fight against money laundering and terrorist activity financing.

Priorities

Pillar 1: Promote a culture of accountability

A leader has high standards for their team and for themselves. Leaders always seek to be better and promote accountability.

FINTRAC is a place where we value a culture of accountability to each other, to ourselves, and to Canadians. We will maximize the potential of our people, not only by focusing on our current expertise and skills, but also by encouraging horizontal and agile ways of working, empowering innovative ideas and equipping them with the tools to foster success. Furthermore, we will focus on recruiting people with varied experience, skills and mindsets that embrace the principles of accountability, excellence, curiosity, innovation, and the desire to influence and inspire others by openly sharing their knowledge and expertise. Finally, we will renew our focus on results and performance to optimize our effectiveness and efficiency in the delivery of our mandate without compromising the values and ethics of our organization. In short, we will ensure that everything we do is driven by, reflects and enhances the Centre's priorities and core values.

Outcome

A resilient, agile workforce accountable for achieving the Centre's priorities within a culture that values diversity, collaboration, civility and ethical behaviour.

Priority 1: Maximize the potential of our people

• Encourage a respectful, inclusive and performance-driven culture that is based on trust and promotes accountability, civility and ethical behaviour
• Maintain a high-level of employee engagement that supports a culture of excellence
• Attract, recruit, retain, and manage our talent effectively and strategically to ensure that our people have the technical and behavioural competencies, agility and mindset to position the Centre and its people for success in a constantly evolving landscape
• Strengthen and leverage internal talent by promoting and facilitating horizontal and agile approaches to the way we work

Priority 2: Ensure transparency through results and performance

• Strengthen our performance measurement framework and regularly report on results
• Proactively engage with, and support various government oversight bodies
• Enhance internal communications and encourage information sharing

Pillar 2: Prepare FINTRAC for the future

Leaders are at the forefront and are an example for others. Leaders are one step ahead and are prepared for the future.

The global financial sector is rapidly evolving, becoming increasingly transnational and technologically innovative. At the same time, the perpetrators of money laundering and terrorist activity financing are also becoming more sophisticated. In order to position ourselves as a trusted leader in the global fight against money laundering and terrorist activity financing, we must look to the future and prepare ourselves for the changes that lie ahead. We will do this by modernizing our workplace to ensure that we have a solid foundation upon which we can explore and implement innovative solutions.

Outcome

A work environment that supports innovation and provides the support and tools, especially information and data, to deepen our analysis and approaches.

Priority 3: Modernize the workplace

• Implement a strategic, enterprise approach to managing our infrastructure, applications, and data
• Implement tools and processes that will effectively enable collaboration, mobility and information sharing
• Leverage our information technology and systems to enhance outcomes

Priority 4: Explore and implement innovative solutions

• Foster a culture that enables innovative approaches to our business, which includes policy, technology, and processes
• Strive for continuous growth and excellence, implement a centre-wide approach to learning and training at the Centre so as to support all areas of organizational learning including corporate training, leadership development, executive training and functional business line training
• Leverage our knowledge and expertise to identify future trends and address possible challenges
• Investigate opportunities for private sector engagement and partnerships

Pillar 3: Collaborate to strengthen results

Leaders listen. Leaders are transparent and work with others.

FINTRAC's financial intelligence supports Canada's broader policing, national security and foreign policy priorities, including in relation to the links between money laundering and criminal activity, and the resourcing of terrorist groups. In order to be a trusted leader in the global fight against money laundering and terrorist activity financing, it is critical that FINTRAC continues to strategically reach out to businesses, law enforcement, international and domestic stakeholders and academia to ensure regime-wide value. By identifying and cultivating purposeful relationships, we will maximize the value of our contribution and efforts. We will also constructively engage stakeholders to find better ways of doing business both externally, and cross-government.

Outcome

FINTRAC leverages the knowledge and expertise of our domestic and international partners to influence change in the way we detect and deter ML and TF activities.

Priority 5: Cultivate strategic relationships with key external stakeholders

• Regularly identify, review, and prioritize FINTRAC's relationships with key business and international stakeholders to ensure their alignment with the Centre's compliance, intelligence, and corporate priorities, while remaining in line with FINTRAC's requirement to be independent and operate at arm's length from the police services, law enforcement agencies and other entities to which it is authorized to disclose financial intelligence
• Play a leadership role in international fora to support the government's broader international efforts to combat money laundering and terrorist activity financing
• Work with external stakeholders to discover new ways of doing business
• Enhance transparency and demonstrate progress with external stakeholders

Priority 6: Strengthen cross-government cooperation

• Proactively work with other Canadian government departments/agencies to increase our influence on government policy-making and decision-making on matters related to money laundering and terrorist activity financing
• Work with central agencies in creating more efficient and effective interactions

A PDF copy of the 2019–24 Strategic Plan is available on the FINTRAC public website: https://fintrac-canafe.canada.ca/publications/plan/strategic_plan-eng.pdf

Overview of Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)

PCMLTFA Objectives:

• To implement specific measures to detect and deter money laundering (ML) and the financing of terrorist activities (TF) and to facilitate the investigations and prosecution of ML and TF offences;
• To respond to the threat posed by organized crime by providing law enforcement officials with the information they need to deprive criminals of the proceeds of their criminal activities, while protecting individual privacy;
• To help fulfill Canada's international commitments to fight transnational crime; and
• To enhance Canada's capacity to take targeted measures to protect its financial system.

Part 1: Reporting entity obligations

Reporting entities (REs):

Part 1 of the Act and related regulations establish to whom the obligations apply:

• Financial entities: banks, authorized foreign banks, cooperative credit societies, savings and credit unions, caisses populaires, financial services cooperatives, credit union centrals (when they offer financial services to anyone other than a member entity of the credit union central), trust and/or loan companies, and agents of the Crown that accept deposit liabilities;
• Life insurance companies, brokers and agents;
• Securities dealers;
• Money services businesses (MSBs) and foreign MSBs;
• British Columbia notaries (when carrying out certain activities on behalf of their clients);
• Legal counsel (inoperative following a decision of the Supreme Court of Canada);
• Accountants (when carrying out certain activities on behalf of their clients);
• Real estate brokers or sales representatives and developers (when carrying out certain activities);
• Dealers in precious metals and stones;
• Casinos; and
• Agents of the Crown that sell money orders.

Obligations:

Part 1 of the Act and related regulations also establish obligations for REs with respect to the following matters:

• Reporting;
• Record keeping and client identification;
• Third party determination;
• Establishing and maintaining a compliance regime (policies and procedures, training, risk assessment, etc.);
• Registering with FINTRAC if the reporting entity is an MSB, foreign MSB, or an agent of the Crown that sells money orders;
• Determining whether a person is a Politically Exposed Foreign Person or a Politically Exposed Domestic Person; and
• Entering into and maintaining a correspondent banking relationship (for financial entities only).

Reports:

Part 1 of the Act and related regulations require REs to report the following to FINTRAC:

• Suspicious transactions;
• Large cash transactions ($10,000 or more);
• International electronic funds transfers (EFTs) ($10,000 or more);
• Terrorist property; and
• Casino disbursements.

Part 1.1: Protection of Canada's Financial System (Ministerial Directives)

Part 1.1 gives the Minister of Finance the authority to issue directives that require reporting entities to apply countermeasures to transactions coming from or going to designated foreign jurisdictions or entities, and recommend the introduction of regulations to restrict REs from entering into a financial transaction coming from or going to designated foreign jurisdictions or entities. The authorities under Part 1.1 were executed for the first time on December 9, 2017.

Part 2: Cross-border movements of currency and Monetary Instruments

Part 2 of the Act and related regulations require anyone transporting currency or monetary instruments of $10,000 or more, into or out of Canada, to file a report with the Canada Border Services Agency (CBSA). Reports of all seizures of currency or monetary instruments of $10,000 or more are sent to FINTRAC by CBSA. FINTRAC has no responsibilities under Part 2, which is administered by CBSA under the responsibility of the Minister of Public Safety.

Part 3: Financial Transactions and Analysis Centre of Canada

Part 3 of the Act establishes the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). It operates at arm's length and is independent from law enforcement agencies and other disclosure recipients, and collects, analyzes and discloses information to help detect, prevent and deter ML and TF in Canada and abroad, and in order to assist the Minister in carrying out his powers and duties under Part 1.1.

Part 3 of the Act enables FINTRAC to receive reports about financial transactions, cross-border movements of currency and monetary instruments, information provided by police and other government agencies and information about suspicions of ML or TF provided by the public. FINTRAC can also collect publicly available information considered relevant to money laundering or the financing of terrorist activities. This includes accessing commercially available databases. In cases where FINTRAC has entered into an agreement, the Centre may also access databases maintained by a government for the purposes of law enforcement or national security.

FINTRAC's mandate to receive detailed financial transaction information is balanced by clear legislative limits on what information can be disclosed (designated information); to whom such information can be provided; and the need for FINTRAC to meet one or more statutory thresholds to disclose financial intelligence.

Disclosure of designated information

Part 3 of the Act also defines the specific legislated thresholds that FINTRAC must meet in order to disclose "designated information" to the following recipients:

• Appropriate police force, if FINTRAC has reasonable grounds to suspect that designated information would be relevant to investigating or prosecuting a ML or TF offence.

The following organizations receive disclosures only if two threshold tests are met: first, FINTRAC has reasonable grounds to suspect that designated information would be relevant to investigating or prosecuting a ML or TF offence, and second, an additional threshold related to the specific disclosure recipient is also met: 

• Canada Revenue Agency (CRA), if FINTRAC also has reasonable grounds to suspect that the information would be relevant to investigating or prosecuting an offence of obtaining or attempting to obtain a rebate, refund, or credit to which the person or entity is not entitled, or of evading or attempting to evade paying taxes or duties imposed under an Act of Parliament administered by the Minister of National Revenue;
• Canada Revenue Agency (CRA), if FINTRAC also has reasonable grounds to suspect that the information would be relevant to determining whether an entity meets the requirements for being a registered charity;
• Canada Border Services Agency (CBSA), if FINTRAC also has reasonable grounds to suspect that the information is relevant to an offence of evading or attempting to evade paying taxes or duties imposed under an Act of Parliament administered by CBSA;
• Canada Border Services Agency (CBSA), if FINTRAC also determines that the information is relevant to determining whether a person is inadmissible to Canada; or is relevant to certain offences under the Immigration and Refugee Protection Act;
• Canada Border Services Agency (CBSA), if FINTRAC also determines that the information is relevant to investigating or prosecuting an offence of smuggling or attempting to smuggle goods subject to duties or an offence related to the importation or exportation of goods that are prohibited, controlled or regulated under the Customs Act or any other Act of Parliament;
• Communications Security Establishment (CSE), if FINTRAC also determines that the information is relevant to CSE's mandate to acquire and use information from the global information infrastructure for the purpose of providing foreign intelligence in accordance with the Canadian government's intelligence priorities;
• An agency or body that administers the securities legislation of a province, if the Centre also has reasonable grounds to suspect that the information would be relevant to investigating or prosecuting an offence under that legislation;
• In addition to the above mandatory disclosures for ML and TF, FINTRAC may also disclose designated information to foreign FIUs when it has reasonable grounds to suspect that designated information would be relevant to investigating or prosecuting an ML or TF offence or an offence that is substantially similar to an ML or TF offence. Such a disclosure can only occur if the FIU has powers and duties similar to FINTRAC's, an agreement meeting the requirements set out in the Act has been signed and if the disclosure of information would not result in a substantial risk of mistreatment of an individual. FINTRAC is responsible for determining the level of risk associated with the disclosure of, request for, or use of information to or from a foreign partner and applying the appropriate mitigating measures. As such, there is ongoing assessment of the risks of mistreatment of an individual by a foreign entity associated with FINTRAC's exchange of information with foreign entities; and
• Finally, FINTRAC must disclose designated information to the Canadian Security Intelligence Service (CSIS), if FINTRAC has reasonable grounds to suspect that the designated information would be relevant to threats to the security of Canada.

In addition to the threats-related disclosures made by FINTRAC to CSIS, the following organizations receive threats-related disclosures only if two threshold tests are met: First, FINTRAC has reasonable grounds to suspect that designated information would be relevant to threats to the security of Canada, and second, an additional threshold related to the specific disclosure recipient is also met: 

• The appropriate police force, if FINTRAC also has reasonable grounds to suspect that the information is relevant to investigating or prosecuting an offence under Canadian law that FINTRAC has reasonable grounds to suspect arises out of conduct constituting a threat;
• The Canada Border Services Agency (CBSA), if FINTRAC also has reasonable grounds to suspect that the information is relevant to determining whether a person is inadmissible to Canada or is relevant to certain offences under IRPA;
• The Canada Border Services Agency, if FINTRAC also has reasonable grounds to suspect that the information is relevant to investigating or prosecuting an offence of smuggling or attempting to smuggle goods subject to duties or an offence related to the importation or exportation of goods that are prohibited, controlled or regulated under the Customs Act or under any other Act of Parliament; and
• The Department of National Defence (DND) and the Canadian Forces, if FINTRAC also has reasonable grounds to suspect that the information is relevant to such a threat as it relates to the Department or to the Canadian Forces.

Director's Authorities under the PCMLTFA

The Director may be required to review denials and revocations of the registration of MSBs or foreign MSBs, as well as administrative monetary penalties (AMPs) issued by the Centre. FINTRAC can revoke and deny MSB or foreign MSB registrations and propose an AMP to persons and entities (reporting entities) found to be in non-compliance with the PCMLTFA. The PCMLTFA allows affected persons and entities to request a review of an MSB or foreign MSB denial of registration, MSB or foreign MSB revocation of registration, or AMP, with the Director of FINTRAC.

The PCMLTFA specifically sets out the Director's authority and the parameters of the review processes. In order to support the Director in these review processes, the Centre created the Reviews and Appeals Unit (RAU), which is an independent unit residing in the Enterprise Policy, Research and Programs (EPRP) Sector, and is responsible for administering the review processes. RAU also conducts reviews with the objective of providing the Director with recommendations and a draft decision. Review officers consider all reviewable aspects of a disputed violation, analyze the representations and make recommendations relative to the violations and whether to impose, reduce or cancel the penalty. At the conclusion of the review process, the Director issues a Notice of Decision (NoD) which, in the case of an AMP, either upholds, modifies or revokes the penalty outlined in the original Notice of Violation (NoV) and, in the case of MSB or foreign MSB denials and revocations of registration, upholds the decision or substitutes with his/her own. The authority to make a decision lies with the Director. The Director must decide, on balance of probabilities, whether the person or entity has committed the violations, and whether to impose a penalty.

Reporting to the Minister

FINTRAC is an agency within the Minister of Finance's Portfolio and the Minister of Finance is responsible for the Centre. The Director is required to report to the Minister on the exercise of the Director's powers and the performance of his or her duties and functions under this Act. In addition, the Director has different reporting requirements further described in the "Reports & Reviews" section below.

The Director shall also keep the Minister informed of, and the Minister may direct the Centre on, any matter that could materially affect public policy or the strategic direction of the Centre.

Feedback, Research and Public Education

FINTRAC can do the following:

• Provide general feedback to reporting entities concerning measures taken regarding reports that they have submitted. (Macro level).
• Conduct research into improved ways of detecting, preventing and deterring money laundering and terrorist activity financing, including related trends and developments.
• Take measures to inform the public, reporting entities, authorities involved in investigating and prosecuting money laundering or terrorist activity financing offences, and others of the following:
  • Their obligations under the Act;
  • The nature and extent of money laundering and terrorist activity financing in and outside of Canada; and
  • Measures taken to combat money laundering and terrorist activity financing, and their effectiveness.

Reports & Reviews

• Annual Report: Each year, on or before September 30, the Director must submit an annual report to the Minister of Finance. This report, which is about FINTRAC's operations for the preceding fiscal year, is then tabled in Parliament by the Minister.
• Compliance Report: Each year, on or before September 30, the Director must submit an annual report to the Minister of Finance that includes a description of the measures taken to ensure compliance with the Act and of FINTRAC's conclusions with respect to compliance; any measures taken to inform police, REs and the public with respect to ML and TF; a description, with statistics, of the results achieved by and the effectiveness of FINTRAC in the exercise of its powers and the performance of its duties and functions; and information on any matters that the Minister or an officer in the Department of Finance specifies.
• Review of Act by Parliamentary Committee: Every five years, the administration and operation of the Act shall be reviewed by the committee of the House of Commons, of the Senate or of both Houses that is designated or established for that purpose.
• Review by Office of the Privacy Commissioner (OPC): Every two years, the OPC reviews FINTRAC's measures to protect information received or collected.

Protection of privacy

There are numerous safeguards to protect the privacy of individuals about whom information is sent to FINTRAC, including the following:

• FINTRAC's arm's length from police, law enforcement and other agencies to which the Centre is authorized to disclose designated information;
• Criminal penalties for any unauthorized use or disclosure of the personal information under FINTRAC's control (Part 5 of the Act);
• A court order is required to obtain information from FINTRAC beyond the designated information disclosed;
• FINTRAC and its employees are immune from compulsory processes (subpoenas, summons, productions orders, etc.) except in very limited circumstances;
• The Privacy Act applies to FINTRAC; and
• Review by the Privacy Commissioner.

Part 4: Regulations

Regulations made under this Act:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
• Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations
• Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations
• Cross-border Currency and Monetary Instruments Reporting Regulations
• Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations
  • Part 4.1 of the Act gives FINTRAC authority to issue administrative monetary penalties in instances where reporting entities do not comply with their obligations under Part 1.

Part 4.1: Notices of violation, Compliance agreements and penalties

Part 4.1 of the Act sets out the authorities and processes related to the issuance of Notices of Violation, compliance agreements and Notices of Decision to entities that are found to be in non-compliance under Part 1. The processes include an administrative review by the Director, appeals to the Federal Court, public naming and collection of penalties.

Part 5: Offences and Punishment

Part 5 of the Act provides criminal penalties for contraventions of the Act, such as unauthorized disclosure or unauthorized use of information under FINTRAC's control, or non-compliance with Part 1 (reporting entity obligations) or Part 2 (cross-border movements).

Pandemic Response

FINTRAC was proactive in preparing for and responding to the COVID-19 pandemic. There are some unique elements that set us apart from other Government of Canada (GoC) organizations, including how quickly we started to prepare for our response (December 2019), the need to manage our response in a highly secured environment where remote work was not a previously common practice and our role as principal federal tenant at 234 Laurier West, with additional regional offices.

In late December 2019, our Security/BCP Team began assessing the initial reports of COVID-19's impacts in Asia. Anticipating a public health crisis could plausibly develop, the Chief Security Officer directed that a review and update of the Centre's Business Continuity Plan (BCP) and Pandemic Annex be conducted to prepare for a potential mobilisation. All Sector BCP leads were engaged and reviewed the Pandemic Annex. In late January 2020 the Pandemic Business Continuity Committee (PBCC) was activated and co-chaired by the Deputy Director of Enterprise Policy, Research and Programs and the centre's Chief Human Resource Officer to begin planning and coordinating FINTRAC's early response activities.

Early decisions through the initial “pre-lockdown” period included expanding remote bandwidth concurrent users from 30 to 200 connections, aggressively prioritizing critical work and Ministerial priorities, advance purchasing cleaning and sanitization supplies and finalizing the Centre's Telework Directive in anticipation of potential pandemic contingency plans. These early actions helped position the Centre for a swift and smooth transition to the new environment that followed lockdowns across the country.

Similarly, early governance steps to include Office of Primary Interest (OPI) from Communications, Occupational Health and Safety, Accommodation, Finance, IM/IT, regional and sectoral business leads helped build consensus for action and frequent communication to Managers, staff and external partners, particularly reporting entities.

The Crisis Management Team (CMT) was formally activated on March 13, 2020, and is made up of the Centre's most senior Executives and select functional leads including the Chief Security Officer (CSO), Communications, Accommodations, Finance and Occupational Health and Safety (OHS). Key members were assigned specific roles of monitoring Public Health Authorities guidance and maintaining ongoing communication with GoC central agencies to ensure continued adherence to guidance, and the principles and DM Framework set forward via the Guidebook for Easing Restrictions.

The Agency was therefore well positioned to respond to the immediate OHS requirements as well as the continuity of critical business functions brought about by the lockdown measures. Once the scope of the lockdowns was understood, the CMT and PBCC planned for continual on-site rotations of Intelligence, IM/IT and other core enablers in Security and Accommodations to maintain critical activities and services throughout the early days. Numbers of on-site employees gradually increased in line with public health directives, to enable critical and priority work that could only be delivered onsite given the sensitive nature of the information involved and need to access secure networks. Other critical business needs were identified in terms of advancing urgent Ministerial priorities that required on site IM/IT presence, notably the time-sensitive execution of the Minister Directive on Iran on July 25, 2020, and implementation of planned regulations by June 2020 and June 2021, respectively.

With the creation of a new Business Resumption Committee (BRC) in early May, additional focused planning on resuming operations yielded a number of successful initiatives for CMT consideration and approval including: a Safe at Work Playbook and Manager's Toolkit; contact tracing application; employee survey; an interim ad-hoc attendance monitoring and a subsequent building access management application deployed to all staff in order to manage building occupancy and support efforts to achieve 100% business resumption without 100% building occupancy; and maximizing remote working solutions for unclassified environments (now at full capability). It is worth noting that the OPI community not only led efforts related to COVID-19 but also maintained core programs and services to management and employees.

Furthermore, as the major tenant at 234 Laurier West, FINTRAC coordinated OHS requirements/access procedures for all other interdepartmental stakeholders. We also liaised heavily with the Department of Finance in terms of substantive business priorities and with Government of Canada leads on pandemic crisis management. We were pleased to present to the PSPC-led ADM table on pandemic management to share best practices we had adopted as a small agency with a top secret security profile and the need to maintain continual on-site presence.

The majority of the Centre is now fully operational with few exceptions where employees are working on a rotation basis on premise due to their functions. Efforts are well underway to address this final step of achieving 100% business resumption consisting of: continuing to adapt existing business practices to optimize the use of technology and virtual techniques; augmenting our technology to support enhance remote working effectiveness; and optimizing the use of our building by providing increased safe access to those employees whose functions requires them being on premises.

We have initiated a lessons learned exercise to assess forward adjustments to our BCP based on our experience throughout the pandemic. Preliminary results indicate that FINTRAC was successful in several areas. The proactive preparation we engaged in through the winter meant that we were ready when the lockdowns were initiated in mid-March. The modified pandemic governance we established early on promoted cohesion and quick decision-making. Timely and transparent communications throughout the pandemic on status and policy changes ensured that FINTRAC employees were well informed; communication included weekly inspirational messages from the Director/CEO for the first few months. Meanwhile, the use of a "three pillars" approach was taken to manage our COVID-19 pandemic response: focus on the physical and mental safety of employees; provide required support to continue work from both the National HQ and home locations; and maintain a laser focus on priority-setting to deliver on the core mandate of the centre. Nonetheless, some areas will require further analysis, including a more flexible definition of what constitute critical functions and when they need to resume operations, adjusting emergency/crisis planning horizons to cover longer duration events such as the current pandemic, redeploying internal space to assign to those who must work from the office given their requirement to access classified systems for instance, and back-up site readiness to allow access in a pandemic. Preliminary findings from an ongoing audit led by Office of the Privacy Commissioner (OPC) is expected to make a recommendation on harmonizing the Centre's BCP template with the TBS Directive on Security Management. Consequently, the CSO will incorporate these lessons-learned and the OPC Audit recommendation in the next BCP update cycle.

B. Overviews

FINTRAC Financial Overview

Please note that totals may not add due to rounding.

Executive Office – Financials

Legal Services Sector – Sector Overview

Introduction

Under the Proceeds of Crime (Money Laundering) Act, FINTRAC has the authority to receive its legal services from the Department of Justice or from the private sector. Further to an MOU between FINTRAC and the Department of Justice, the legal services unit is staffed by Justice lawyers whose role is to provide high quality, helpful and timely advice to FINTRAC on all legal questions pertaining to the Center's mandate and operations. In addition to drawing on their own knowledge and expertise, the lawyers in the unit have the ability to call upon experts elsewhere in Justice, such as those dealing with the Charter or criminal law, to assist them in advising FINTRAC.

Executive

Karyne Merrick Moore
General Counsel, Legal Services

Karyne Merrick Moore has been the General Counsel at FINTRAC Legal Services for the last three years, and she is a member of the Centre’s Executive Committee.

After having worked in the Legal Services Unit at FINTRAC from 2006-2009, Karyne spent six years in the National Security Litigation and Advisory Group (NSLAG) of the Department of Justice. At NSLAG, Karyne provided advice and litigation services to client departments and agencies located within Justice Canada’s Public Safety, Defence and Immigration Portfolio. In 2015, Karyne returned to FINTRAC Legal Services as Senior Counsel and, in 2017, she was appointed to the position of General Counsel. In this role, Karyne leads the Legal Services team, which provides advice in relation to all matters dealing with FINTRAC’s operations, with an emphasis on the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Karyne also regularly provides training on legal questions related to FINTRAC’s various mandates to FINTRAC employees and outside stakeholders.

Prior to joining FINTRAC Legal Services, Karyne held the position of Law Clerk to the Chief Justice of the Federal Court of Appeal, and prior to this, she worked for five years as a policy analyst in the Policing, Law Enforcement and Interoperability Branch of Solicitor General Canada (now Public Safety Canada), through the Federal Student Work Experience Program.

Throughout her more than 20-year career in the federal public service, Karyne has developed expertise in administrative law and national security law, and has acquired extensive knowledge and experience regarding the operations of the various sectors within FINTRAC.

Karyne holds a Bachelor’s degree in Criminology (B.Soc.Sc., Gold Medal), and a Bachelor’s degree in Law (LL.B., French program) from the University of Ottawa, as well as a Master’s degree in Public Law, from the University of Stellenbosch, in South Africa, which she obtained as an Ambassadorial Scholar of the Rotary Foundation. Karyne is a member in good standing of the Law Society of Ontario.

Sector Organization Chart

Legend

ACT = Acting
ASG-I = Assignment In
ASG-O = Assignment Out
INTER-I = Interchange In
INTER-O = Interchange Out
TERM = Term
( ) = Away from substantive
* = Away from sector
Direct reports :
Functional reports :
[REDACTED]

Key Files and Daily Activities of Legal Services

• FINTRAC Committees: Counsel from FINTRAC's Legal Services Unit sit on the Centre's various governance committees and provide legal advice in the context of committee meetings.
• Cullen Commission: Announced in May 2019, by B.C. Premier John Horgan, the Commission has the mandate to study the many typologies of ML in B.C., the effectiveness of AML regime bodies, and make recommendations to address conditions which have enabled money laundering to grow in B.C. The Legal Services team at FINTRAC leads and coordinates the provision of FINTRAC information and documents to the Department of Justice litigation team heading Canada's response to the Cullen Commission.
• Administrative Monetary Penalties: FINTRAC Legal Services is involved in the preparation of Notices of Violation (NOVs) and Notices of Decision (NODs) and provides litigation support in any litigation which may follow the imposition of an AMP by FINTRAC.
• Implementation of Regulations: The Legal Services team provides wide-ranging support to the FINTRAC client in the implementation of an extensive set of regulations made under the PCMLTFA, which will come into force in June 2021. This work includes the provision of legal advice on the operationalization of the new provisions, the review and drafting of guidance, as well as policy and regulatory interpretations.
• Non-Compliance Disclosures (NCDs): FINTRAC Legal Services works with FINTRAC's Compliance Sector in the preparation of NCDs and leads the provision of FINTRAC-related legal advice to police and prosecutors responsible for the investigation and prosecution of non-compliance offences laid under Part 5 of the PCMLTFA. Legal Services is currently providing litigation support and advice to Crown counsel working on non-compliance prosecutions, across Canada.
• Tactical and Strategic Intelligence: Legal Services at FINTRAC works with the Intelligence Sector in the preparation of tactical financial intelligence disclosures related to money laundering, terrorist activity financing and threats to the security of Canada. It also reviews strategic intelligence products to ensure that these products meet the legal requirements set out in FINTRAC's enabling legislation. In addition, the FINTRAC Legal team provides litigation support to Crown counsel and advises them on the use of FINTRAC's intelligence in criminal and other court proceedings.
• Training: The Legal Services team provides training to FINTRAC employees on the legal framework of the PCMLTFA and other relevant legal matters affecting FINTRAC. It also trains external stakeholders, such as international delegations, investigators and prosecutors on the use of FINTRAC's intelligence and evidence.

Legal Services Sector – Financials

Compliance Sector Overview

Introduction

The Compliance Sector supports FINTRAC's vision and mandate by ensuring that approximately 24,000 reporting entities comply with Part 1 and Part 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations.

FINTRAC's National Compliance Program adopts a framework guided by the three principles of Transparency, Engagement and Clarity, and spanning three cornerstone pillars of our work in Assistance, Assessment and Enforcement. The sector's operations are conducted from Headquarters (HQ) and three regional offices.

Compliance HQ is responsible, among other activities, for coordinating the strategic and operational initiatives of the compliance program and providing national leadership for the regional operations, as well as providing assistance to reporting entities, which includes: managing the money services businesses registry, providing policy interpretations, administering FINTRAC's national compliance examination, Administrative Monetary Penalty and Non-Compliance Disclosure programs, and maintaining compliance Memoranda of Understanding with external regime partners.

The three FINTRAC regional offices located in Vancouver, Toronto and Montréal, are responsible for conducting compliance examinations of reporting entities. They are also responsible for providing assistance to reporting entities and maintaining key relationships with other regulators and industry associations.

EXECUTIVE

Donna Achimov
Deputy Director, Compliance Sector / Chief Compliance Officer and
FINTRAC's Official Languages Champion

On September 23, 2019, Donna Achimov was appointed Chief Compliance Officer at the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Prior to her nomination as the Deputy Director of Compliance sector, Donna had served as the Deputy Director of FINTRAC’s Corporate Management Services sector and Chief Financial Officer. She is an experienced leader who has held numerous positions within the Government of Canada, including CEO of the Government of Canada’s Translation Bureau and Assistant Deputy Minister for Human Resources at Public Services and Procurement Canada. Donna has managed extensive regional operations as part of her role in establishing a national service delivery network for Service Canada. She has also served as Acting Assistant Deputy Minister, Receiver General and Pensions, where she gained insight into Canada’s banking industry and the complexity of risk management.

Donna is an inclusive leader and has made an impact inside and outside the Government of Canada. She has been integral in helping to shape the public service innovation agenda and culture of openness, transparency and integrity. She intuitively sees the threads of opportunity when it comes to streamlining operations and lessening reporting burden on Canadians and businesses. Respected as a credible voice in decision-making, she has a reputation for collaborating with strategic partners, federal, provincial, municipal and territorial counterparts, as well as industry in order to support FINTRAC’s vision, Safe Canadians, Secure Economy.

In her past role as Chair of the Board of Directors for the Association of Professional Executives of the Public Service of Canada (APEX), she was (and remains) a strong advocate for respectful workplaces, and actively promotes health and well-being across the federal public service.

Donna holds an Honours Bachelor’s degree in journalism from Carleton University. She is also a graduate of the Directors Education Program from the Institute of Corporate Directors at the Rotman School of Management, University of Toronto.

She is passionate about changing the public service culture to allow more innovation and creativity and speaks frequently on topics of leadership, mental health, diversity, values and ethics and issues that will affect the next generation of public service leaders.

Sector Organization Chart

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ACT = Acting
ASG-I = Assignment In
ASG-O = Assignment Out
INTER-I = Interchange In
INTER-O = Interchange Out
TERM = Term
( ) = Away from substantive
* = Away from sector
Direct reports :
Functional reports :
[REDACTED]

Overview of Sector Units

Assistant Director, Regional Operations

The Assistant Director, Regional Operations is responsible for the national leadership of the regional operations, with Regional Directors as direct reports. Furthermore, the Assistant Director, Regional Operations is a member of the Management Advisory Committee and the Business Resumption Plan Committee; leads the International Supervisory Forum initiatives, Tier II training portfolio as well as the strategic relationship with the Office of the Superintendent of Federally Regulated Financial Institutions.

Compliance Support Unit (CSU)

The Compliance Support Unit (CSU) has both an operational and support role, as it is responsible for providing direct assistance to reporting entities that are covered under the PCMLTFA and the general public, as well as for coordinating all strategic and operational initiatives that complement and support the other Compliance functions.

Key CSU activities include: responding to enquiries and feedback from reporting entities and the general public; enrolling reporting entities for reporting purposes; managing the money services business (MSB) registration program; managing the Compliance Assessment Report (CAR) program; coordinating corporate initiatives and incoming horizontal requests including strategic planning, corporate reporting, statistical reports, Access to Information and Privacy coordination, review and processing; the review and issuance of all compliance policies, procedures and notices; and oversight on the overall Compliance sector budget. CSU also provides business support for IT-related major projects, significant initiatives and enhancement requests involving Compliance.

Relationship Management Unit (RMU)

The Relationship Management Unit (RMU) is responsible for all compliance strategies related to external stakeholders.

Key activities of the RMU include: providing guidance to reporting entities through FINTRAC website publications, such as guidelines and policy interpretations; leading the Compliance sector's contribution to the Financial Action Task Force mutual evaluation and responding to international requests; overseeing the negotiation and signing of compliance Memoranda of Understanding with other regulators; documenting and assessing voluntary self-declaration of non-compliance (VSDONC) received; conducting and coordinating engagement activities with all reporting entity sectors, including industry associations.

Regional Support Unit (RSU)

The Regional Support Unit (RSU) is responsible for administering the Administrative Monetary Penalty program and providing functional and operational leadership related to compliance assessment and enforcement strategies and plans to the regional compliance officers. The unit's diverse portfolio encompasses a wide range of operational and strategic activities.

Key activities of the RSU include: providing support and guidance to the Regional Compliance Officers; administrating the Compliance sector's data integrity activities; developing and implementing compliance assessment strategies, methodologies and related policies and procedures, and the annual examination plan; reviewing and approving select examination files; developing and managing the Casino compliance strategy; the administration of monetary penalties and non-compliance disclosures; developing and managing compliance systems and tools such as the [REDACTED] implementing and operationalizing legislative and regulatory amendments; assisting with the policy development of new legislative and regulatory amendments; chairing and managing the National Citing Committee; and providing operational expertise on compliance programs.

Regional Offices

The three regional offices are responsible for delivering the compliance program across Canada. Key activities include: conducting compliance examinations, providing compliance guidance, and participating in engagement activities such as compliance meetings, presentations and consultations with reporting entities, as required. FINTRAC's regional offices are also responsible for managing partnerships with provincial regulators (such as the BC Financial Services Authority, the Autorité des marchés financiers, the Investment Industry Regulatory Organization of Canada), and with Memoranda of Understanding partners.

Vancouver Office

The Vancouver office is responsible for compliance program delivery in all provinces West of Ontario and all territories as well as the relationship management of Major Reporters within their geographic portfolio.

They are additionally responsible for the Casino sector in the province of Ontario.

Montréal Office

The Montréal office is responsible for compliance program delivery throughout Quebec and the Maritimes as well as the relationship management of Major Reporters within their geographic portfolio.

They are also responsible for certain sectors in Ontario: credit unions; real estate; accountants; dealers in precious metals and stones; and life insurance that are not part of a federally regulated conglomerate; and MSBs and securities (not part of a federally regulated conglomerate) with postal code areas starting with K and P.

Toronto Office and Major Reporters Function

The Toronto office is responsible for the compliance program delivery of banks, trust and loans, life insurance and securities dealers that are part of a conglomerate as well as the relationship management of Major Reporters within their geographic portfolio.

They are also responsible for MSBs and other securities dealers located within and around the greater Toronto area defined as those areas with postal codes beginning with L, M and N. In addition, the Toronto office supports the Regional Support Unit with oversight for the banking sector within Compliance.

Compliance Sector – Financials

Intelligence Sector – Sector Overview

Introduction

The role of the Intelligence Sector is to deliver relevant, high quality, timely and actionable financial intelligence to domestic law enforcement (LE), national security agencies (NS) and other partners, and to share, as appropriate, intelligence with Financial Intelligence Units (FIUs) in foreign jurisdictions.

The Sector produces tactical disclosures which include reports the Centre receives from Reporting Entities (entities covered under the PCMLTFA), Canada Border Services Agency (CBSA) It also receives and assesses information voluntarily provided by LE, NS, FIUs and others.

The Sector discloses tactical financial intelligence both reactively (in response to received voluntary information) and proactively (based on suspicious transaction reports (STRs) or open source information), pursuant to appropriate legal thresholds. It also produces Operational Alerts, financial intelligence briefs and other type of intelligence assessments.

Executive

Barry MacKillop
Deputy Director, Intelligence Sector

Barry first joined FINTRAC in September 2011 as the Deputy Director of the Financial Analysis and Disclosures (Intelligence) Sector. He became the Deputy Director of Operations (Compliance and Intelligence Sectors) in November 2015. In 2019, following a reorganization, he joined the Intelligence Sector as their Deputy Director.

Prior to this, Barry worked at Public Safety Canada where he held various senior positions over nine years including that of Director General of Law Enforcement, Organized Crime and Border Strategies, Senior Director of National Strategies (Serious and Organized Crime) and Director of Summit Security, Contract Policing and Firearms Policy. Barry began his career in the non-profit sector with the Youth Services Bureau of Ottawa and has also held positions in other federal government organizations, including both the Privy Council Office and Treasury Board of Canada Secretariat.

Barry holds a Master of Arts Degree in Criminology from the University of Ottawa.

Sector Organization Chart

Legend

ACT = Acting
ASG-I = Assignment In
ASG-O = Assignment Out
INTER-I = Interchange In
INTER-O = Interchange Out
TERM = Term
( ) = Away from substantive
* = Away from sector
Direct reports :
Functional reports :
[REDACTED]

Overview of Sector Units

Terrorist Financing / Threats Unit (TF/TH)

The Terrorist Financing & Threats Unit is responsible for analyzing voluntary information submitted by, and, where appropriate, disclosing under the TF/TH mandate to LE and NS partners. These operational partners may include the Royal Canadian Mounted Police (RCMP), Canadian Security Intelligence Service (CSIS), Communications Security Establishment Canada (CSEC), CBSA, Canada Revenue Agency (CRA) - Charities, Canadian Armed Forces (CAF), Provincial Police Services (Ontario - OPP and Québec - SQ), and municipal police services. The Unit is the lead on international operational relationships with other Financial Intelligence Units (FIUs) regarding both ML and TF-related queries and casework. The Unit also leads Suspicious Transaction Report (STR) triaging and classified information assessment with a view of generating relevant proactive casework across the Sector. Finally, the Unit maintains operational relationships with the above-mentioned partners while contributing to national and international-level joint efforts to combat terrorist financing. TF/TH is divided into three teams. 

Western / Eastern Region (WERDU)

The Western and Eastern Regions Anti-Money Laundering (AML) Unit (WERDU) is responsible for maintaining operational (AML) relationships with federal, provincial and municipal law enforcement agencies in Western (British Columbia, Alberta, Saskatchewan, and Yukon) and Eastern Canada (Quebec and the Atlantic Provinces), including the analysis of voluntary information submitted by these partners. WERDU also maintains operational relationships with the Securities Commissions in those two regions, CRA, CBSA, and Revenu Québec. WERDU is divided into four teams.

Central Region Unit (CRU)

The Central Region Anti-Money Laundering (AML) Unit (CRU) is responsible for maintaining (AML) operational relationships with federal, provincial and municipal law enforcement agencies in Central Canada (Ontario, Manitoba, the Northwest Territories, and Nunavut), including the analysis of voluntary information submitted by partners. CRU also maintains operational relationships with the Ontario and Manitoba Securities Commissions, the Competition Bureau of Canada, and the Department of National Defense (AML). CRU is divided into three teams.

Modernization, Integration & Targeted Trends Analysis Unit (MITTA)

Modernization, Integration & Targeted Trends Analysis Unit (MITTA) maintains a number of functions within one unit. "Modernization" includes responsibility for working in collaboration with the IM/IT Sector for the development and maintenance of the IM/IT systems and business in the Sector, while continuously seeking to increase the efficiency and quality of operations in both the short and long run. "Integration" refers to Operational & Integration Support which leads the Sector in terms of processing intelligence received from external agencies and coordinating the disclosure process to ensure timely delivery of financial intelligence to domestic and international partners. It is further responsible for developing / maintaining the policies and procedures that govern tactical intelligence work, responds to statistical requests, coordinates Access to Information (ATI) and Privacy Act requests for the Sector and serves as the liaison with other sectors to contribute to all FINTRAC Corporate activities. It also leads on orientation, core skill building and training initiatives for the Intelligence Sector.

Targeted Trends Analysis (TTA) is responsible for research, analysis, and writing financial intelligence reports, Operational Alerts and assessment products, of a more macro nature, based on financial transaction data and disclosure information for Sector partners and in support of Private Public Partnerships (PPPs). TTA is responsible for drawing inferences, designing and carrying out a wide range of analytic tasks, and providing intelligence in relation to the ML/TF methods and techniques associated with individuals, jurisdictions, and financial entities used by or associated with priority ML/TF threat actors.

Key Files and Daily Activities of the Financial Intelligence Program

• Analyze and assess Voluntary Information Records (VIRs) and Financial Intelligence Unit (FIU) queries received from our law enforcement/national security partners and international FIUs, respectively, as well as Suspicious Transactions Reports (STRs) submitted to FINTRAC by Reporting Entities. The Sector also analyzes similar information (VIRs) received by others (government and non-government) and the public.
• Develop and disclose actionable financial intelligence to Canada's law enforcement/national security agencies, and FIUs, in the form of financial intelligence disclosures (including contributions to project-level (major) investigations at the municipal, provincial and federal levels as well as five (5) Public-Private Sector Partnership (PPP) initiatives).
• Pro-active focus on FINTRAC's five PPP initiatives (PROTECT (human trafficking), CHAMELEON (romance fraud), GUARDIAN (fentanyl trafficking), ATHENA (money laundering through underground banking), and SHADOW (online child sexual exploitation).
  • Assess and analyze STRs received by our senior analysts leading each initiative.
  • Develop and disclose proactive actionable financial intelligence to key law enforcement partners.
  • Explore the possibility of adding new PPP initiatives by continuing to nurture an open-dialogue with PPP partners (REs, LE and FINTRAC stakeholders).
• Produce strategic intelligence products for law enforcement and intelligence partners, including Operational Alerts, which provide indicator-based information for Reporting Entities, disclosure recipients and the general public on specific money laundering and terrorism financing issues, with a focus on methods, trends, threats, and vulnerabilities.
• Enhance tactical disclosures by enriching the toolkit available to assist Intelligence Sector analysts, including the refinement of indicators and providing ongoing training.
• Continue to explore and implement changes to both our analytical applications as well as our financial intelligence cycle (intake to disclosure production) in order to increase efficiencies and operationalize legislative changes impacting the Intelligence Sector's Disclosure product.
• Monitor national and international events related to money laundering and terrorist financing to enable the assessment of implications for Canada and facilitate proactive and reactive disclosures as warranted.
• Continue to engage in various outreach activities to enhance awareness and understanding of FINTRAC and the overall value of our financial intelligence.

Intelligence Sector – Financials

Enterprise, Policy, and Research Development (EPRP) - Sector Overview

Introduction

The Enterprise Policy, Research and Programs (EPRP) sector was established in a wide-ranging reorganization of the Centre in September 2019, aligned to a Strategic Vision exercise. The reorganization consolidated strategic policy, research and corporate functions so as to better position the Centre to integrate and evolve the Compliance and Intelligence mandates while maintaining appropriate independence between these functions.

The EPRP sector is responsible for the development and coordination of FINTRAC's domestic and international strategic policy, research, and academic outreach and actively engages with key government organizations such as Finance Canada, Public Safety Canada and the Privy Council Office to inform the legislative and regulatory change agenda. It is also responsible for the production of strategic financial intelligence that assists decision-makers in reducing money laundering/terrorist financing (ML/TF) risks and degrading the capacity of illicit financial actors to launder the proceeds of crime and/or finance terrorism.

Given the mandate of the Centre and its responsibilities for the protection of Canadian's privacy, EPRP is responsible for ensuring a robust Piracy Protection and Privacy Impact Assessment program to guide the Centre activities involving the collection and use of personal information, and ensures all facets of FINTRAC's operations are subject to rigorous security measures that safeguard the Centre's physical premises and IT systems, and include the handling, storage and retention of all personal and other sensitive information under its control. 

Additionally, EPRP serves as a key partner in the delivery of the Centre's core programs through its responsibilities in delivering sound corporate programs including communications, finance and administration (including procurement and accommodations), integrated business planning and reporting, and accountability assurances as part of the management review and evaluation program.

Executive

Annette Ryan
Deputy Director, Enterprise Policy, Research and Programs (CFO)

Annette Ryan is the Deputy Director of the Enterprise Policy, Research and Programs sector of FINTRAC and the Chief Financial Officer. In this role, she is responsible for advancing the current and forward agenda of the Centre through strategic cohesion and leadership across policy, research and corporate enabler functions.

Previously as Associate Assistant Deputy Minister of the Financial Sector Policy Branch, at Finance Canada, she led policy development on federal financial sector policy issues including financial innovation, cross-border trade in financial services, cyber security and anti-money laundering and anti-terrorist financing. While Director General of Employment Insurance Policy at Employment and Social Development Canada, Annette led the implementation of a broad suite of commitments from the incoming Liberal government election platform, described by the media as "the largest reform to the EI program in 20 years." As Chief Economist at Industry Canada, Annette negotiated wide ranging MOUs with Statistics Canada to link detailed Canadian business data over multiple data sources and through time; building from this data access, she coordinated a wide ranging coalition of academic, labour and business partners to establish a multi-year, SSHRC-funded network to investigate Canadian drivers of firm-level productivity and innovation. In her previous experience with federal and provincial central agencies, including the Privy Council Office and Treasury Board Secretariat, she led policy analysis on varied economic and social policy issues -- including fiscal federalism, labour markets, government expenditure and taxation.

Before joining the public service, Annette conducted research on innovation and labour demand through data analysis of corporations at the Institute for Fiscal Studies in London, U.K. She holds a Masters degree in Economics from Oxford University, which she attended as a Rhodes Scholar, and a Bachelor degree in Mathematics from Acadia University.

Sector Organization Chart

Legend

ACT = Acting
ASG-I = Assignment In
ASG-O = Assignment Out
INTER-I = Interchange In
INTER-O = Interchange Out
TERM = Term
( ) = Away from substantive
* = Away from sector
Direct reports :
Functional reports :
[REDACTED]

Overview of EPRP Sector Units

1. Strategic Policy and Reviews (SPAR)

The SPAR Unit is led by Bruce Wallace Manager, and is currently comprised of teams as follow:

• Domestic Policy Analysis (SPAR-D);
• International Policy and Engagement (SPAR-I); and
• Review and Appeals Unit (RAU).

SPAR leads FINTRAC's policy development work and engagement with key federal policy departments such as Finance Canada, Public Safety Canada and the Privy Council Office. Internationally, SPAR leads FINTRAC's policy development and engagement with the Financial Action Task Force (FATF) and FATF-style Regional Bodies (FSRBs), as well as other international activities such as technical assistance and multilateral and bilateral relations. Finally, SPAR is also responsible for the review and appeals function. It is responsible for the administration of representations made to the Director concerning administrative monetary penalties (AMPs) and applications for review of decisions concerning the registration of a money services business (MSB).

Teams:

Domestic Policy Analysis (SPAR-D) – The Domestic Policy Analysis team manages FINTRAC's policy relationships with domestic partners and is responsible for working with the Department of Finance and other regime partners to address Canada's AML/ATF policy needs. SPAR-D supports the Director's participation in two standing Deputy Minister committees, DM Anti-Money Laundering and DM National Security (Policy). It provides advice to senior management on domestic policy issues, and it chairs the internal Policy Working Group (PWG) for the production of coordinated research in support of policy proposals that advance FINTRAC's mandate and help improve the AML/AFT regime. Additionally, it ensures the harmonization of FINTRAC priorities and policies with those of the Government of Canada, and monitors external reviews and parliamentary affairs to ensure that FINTRAC is up-to-date and involved with processes that could have an impact on the Centre.

Key Files and Duties of SPAR-D:

• Commission of Inquiry into Money Laundering in British Columbia (Cullen Commission)
• Preparation of policy proposals, budget proposals, and Treasury Board submissions
• Working with the Department of Finance on various regime policy files and the Department of Public Safety to provide input on operational matters affecting the Regime.
• Preparation of briefing material for Sector Head and Director for Regime Committee meetings.
• Participation in various working groups and committees in Canada's AML/ATF Regime, and national security community.

International Policy and Engagement (SPAR-I) – The SPAR International Unit leads FINTRAC's policy development and engagement at the international level, including at the Financial Action Task Force (FATF) and the FATF-style Regional Bodies (FSRBs), in close collaboration with the Department of Finance, Global Affairs Canada and other departments and agencies. The SPAR International Unit also leads on the coordination of Egmont Group activities for the Centre, coordinates technical assistance and training, and addresses other multilateral and bilateral initiatives that have an impact on the Centre.

Key Files and Duties of SPAR-I:

• The SPAR International Unit develops and negotiates policy positions and participates in FATF, Caribbean FATF (CFATF) and the Asia-Pacific Group (APG) for the Centre. This includes discussions of FATF mutual evaluation reports and follow-ups, risks and trends, and policy gaps, as well as the monitoring of developments that can have an impact on FINTRAC.
• It also coordinates the Centre's work at the Egmont Group of Financial Intelligence Units and leads on other multilateral and bilateral initiatives that have an impact on the Centre as a whole or on policy development such as UN, OECD and Five-Eyes initiatives and negotiates Memoranda of Understanding for the Centre.
• The SPAR International Unit is responsible for implementing the development and coordination of technical assistance projects and other initiatives that enhance cooperative relationships with other FIUs, supervisors and relevant stakeholders.
• It is also responsible for other files that have an international component such as the implementation of Ministerial Directives on countries that pose a risk to the Canadian financial system and the implementation of Directions on avoiding complicity in mistreatment by foreign entities.

Review and Appeals Unit (RAU) – RAU is responsible for administering two legislative mandates on behalf of the Director, namely the review of representations made by REs contesting notices of Administrative Monetary Penalties (AMPs) that the Centre proposes to impose upon them, and the review of applications contesting revocations or denials of MSB registration. RAU reviews these representations and makes recommendations to the Director to inform her/his decision.

Based on these reviews, the Director issues a Notice of Decision (NoD) imposing the penalty proposed, in the original Notice of Violation (NoV), a lesser penalty or no penalty. In the case of MSB denials and revocations, the Director can uphold the decision or substitute with her/his own.

RAU is independent from the Compliance sector, who administers the MSB Registry and the AMPs Program, to maintain objectivity and avoid bias.

Key Files and Duties of RAU:

• AMPs Reviews, MSB Revocation/Denials Reviews
• Regulatory Amendments

2. Strategic Intelligence, Research and Analytics (SIRA)

FINTRAC's SIRA unit is led by [REDACTED], Manager, and is comprised of a Strategic Intelligence and Research team and an Advanced Analytics team. SIRA supports the Director's participation in one standing Deputy Minister committee, DM Intelligence Assessment. SIRA leads FINTRAC's production of strategic financial intelligence on the nature, scope and threats posed by money laundering and terrorism financing in order to support and inform federal policy and operational decision-makers, domestic and international partners, and other stakeholders. SIRA collaborates with all business lines by developing advanced analytical methods and designing custom data solutions in support of compliance, intelligence, policy and strategic activities across the Centre.

Teams:

• The Strategic Intelligence and Research team consists of strategic intelligence analysts responsible for:
  • Developing and leveraging specialized knowledge and expertise on the nature and extent of money laundering and terrorist financing in Canada and abroad; and
  • Informing anti-money laundering and anti-terrorist financing (AML/ATF) regime partners and the security and intelligence community about priority threats, risks and vulnerabilities.

• The Advanced Analytics team is comprised of multi-disciplinary data scientists/data analysts with a broad range of knowledge and expertise including the Agency's business processes, data, and advanced analytics. Through the use of sophisticated statistical techniques and tools, the Advanced Analytics team uses financial transaction data and other data sources to uncover fact-based insights, make predictions, and generate recommendations that support the Agency's business decisions and improve its processes.

Key and Daily Files of SIRA:

• Producing intelligence assessment products—including financial intelligence reports and research reports—that inform on the nature, capabilities, and intentions of entities and jurisdictions of concern by understanding their financial behavior.
• Contributing to and lead international projects and working groups, such as the analysis developed for the Financial Action Task Force (e.g., FATF's Risks, Trends and Methods Group) and for the Egmont group's capacity building and typology projects.
• Contributing to security & intelligence and law enforcement strategic analyses, and supporting FINTRAC Executive participation in Government of Canada Intelligence and National Security committees.
• Developing products related to the use of advanced analytic techniques such as statistical / quantitative analysis, time series and forecasts, data/text mining, predictive modeling and social network analysis.
• Conducting data analysis to specific questions and derives insights from the Agency's current data holdings and works with partners to expand data sources.

3. Finance and Administration

FINTRAC's Finance and Administration unit is led by [REDACTED], Manager and Deputy Chief Financial Officer, and is comprised of an Accommodation and Administration team, Procurement team, Accounting Operations team, and Resource Management team. Finance and Administration ensures government-wide financial and accounting legislation, directives, regulations and procedures are respected, and provides operational accounting and reporting services, as well as a wide range of administration and procurement services.

Teams:

The Accommodation and Administration team manages all FINTRAC space including 234 Laurier Avenue West and three regional offices located in Vancouver, Toronto, and Montréal. FINTRAC is a fully reimbursing client of PSPC, responsible for all leasing and refit costs.

• Accommodations responsibilities include planning and managing all administration and accommodation moves, supplies and equipment; and maintaining office and office and building equipment (including universal power supplies, generator, air conditioning, etc.).
• Administration manages mail and messenger services to provide a safe delivery system for all incoming mail to FINTRAC, while ensuring the best prices and the most appropriate and secure service for all outgoing mail.

The Procurement team provides guidance, advice and interpretation on government and FINTRAC contracting policies and procedures. The team's responsibilities include: the purchase of goods and services for FINTRAC; providing training and advice; procurement planning and reporting; and, supporting the Contract Review Committee.

The procurement context is unique at FINTRAC. More specifically, the Centre is exempt from trade agreements. Additionally, over and above the general authorities delegated to departments, FINTRAC has three special contracting authorities that were granted either by Treasury Board or through an Order in Council. These special authorities are:

• Specialized software and other related services up to $250,000;
• Goods purchased either on a competitive or non-competitive basis when the contract does not exceed $375,000;
• Legal Services: FINTRAC is authorized to procure Legal Services from outside the Public Service of Canada either on a competitive or on a non-competitive basis.

The Accounting Operations team is responsible for providing advice related to, and the delivery of, a complete range of financial operations services. The team's responsibilities include:

• The management of the Centre's accounts payable and accounts receivable.
• The functional maintenance of the Centre's financial systems.
• Providing advice and guidance related to the full spectrum of financial policies and procedures.
• Reporting to Central Agencies, including proactive disclosure, public accounts and annual financial statements.

The Resource Management team plays a reporting role, both internally (to sectors/directorates, the Management Advisory Committee [MAC], the Executive Committee [EXCO]) and externally (to the Department of Finance, Central Agencies, etc.). The team is responsible for all matters pertaining to financial planning, budgeting, liaising with central agencies for items related to the Expenditure Management System (EMS), and costing. In addition, Financial Management Advisors (FMAs) for each sector are in place to provide guidance and advice in relation to all financial matters.

Key and Daily Files of Finance and Administration:

• The HQ on the Move relocation project is underway to move FINTRAC's headquarters at 234 Laurier Ave to new office space at [REDACTED].
• The Montreal Move is also beginning to relocate the Montreal regional office (October 2021). The project has just formally launched with aggressive timelines. A funding decision is forthcoming. The move comes as a result of end of lease, and the new location [REDACTED]. The design will introduce GC Workplace to the organization.
• Pandemic and Business Resumption Planning activities are ongoing, and F&A is an active member of FINTRAC's response to COVID-19.
• Digital comptrollership program (previously GCFM): FINTRAC was scheduled to implement the GCFM system as part of cohort 2 of departments and agencies, in April 2021. However, due to project delays, the Office of the Comptroller General and TBS determined that the GCFM project team did not have the capacity to onboard FINTRAC as part of cohort 1 in April 2021. There is no firm scheduled date for cohort 2 at this time. FINTRAC is currently exploring the option of onboarding with the IRIS cluster on the current version of SAP to stabilize the Departmental Financial Management and Reporting System (DFMRS) in the interim.
• FINTRAC received $20.5M over 5 years from 2019-20 to 2023-24 and $2.8M ongoing in Budget 2019 for five initiatives: (1) implementing regulations; (2) strengthening FINTRAC compliance, outreach and examinations; (3) expanding FINTRAC public-private partnership projects; (4) new disclosure recipients; and (5) trade fraud and trade based money laundering (TBML) centre of expertise. The resource management, accounting operations and procurement teams are engaged in managing, spending and accounting for these new funds.
• The July 2020 Economic and Fiscal Update (Budget 2020) announced $133.6M on a cash basis ($106.1M on an accrual basis) over 6 years from 2020-21 to 2025-26 and $2.9M ongoing for FINTRAC to (1) address program pressures and modernization (2) support the Headquarters relocation and (3) strengthen Canada's Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) Regime fund. Similar to Budget 2019, the resource management, accounting operations and procurement teams are engaged in managing, spending and accounting for these new funds.

4. Corporate Business Planning and Management (CBPM)

FINTRAC's Corporate Business Planning and Management (CBPM) unit is led by Marie-Anne Bradford, Manager, and is comprised of a Strategic Planning and Enterprise Analysis team, Investment Project Planning and Delivery team, and Management Review, Evaluation and Performance Reporting team.

CBPM supports the Director in ensuring accountability for results as part of the Main Estimates Part III requirements and governed by various Treasury Board Secretariat (TBS) policies, such as the Policy on Results. CBPM is also responsible for the full integrated planning and performance reporting process including the development of the Departmental Plan, Departmental Results Report, Management Accountability Framework (MAF), the Centre's Departmental Results Framework and the assurance program through the implementation of a management review and evaluation program.

CBPM serves as the Project Management Office (PMO) for the Centre and plays an important challenge function with respect to the execution of organizational investments, and leads on the Centre's governance model to support FINTRAC's integrated corporate system of decision-making that enables (1) effective allocation of resources to priorities; (2) alignment of activities to outcomes; and (3) management of accountabilities.

Teams:

The Strategic Planning and Enterprise Analysis (SPEA) team lead the development of the FINTRAC Strategic Plan 2019-24 and the annual integrated planning exercise in close collaboration with colleagues responsible for budget management and procurement, human resources and IM/IT. This annual exercise results in a number of different products including the Departmental Plan and FINTRAC's Integrated Plan. The team works with stakeholders across the Centre to guide the Centre's investment decisions and activities through the use of business analytical tools and techniques, such as facilitated workshops, to elicit, analyze, validate and document business objectives, needs, processes and requirements to identify areas where investments could bring value.

The Investment Project Planning and Delivery team assesses the Centre's investment project proposals against factors such as risk, strategic alignment and business outcomes to recommend a prioritized investment portfolio for governance approval. As the Project Management Centre of Expertise, the team also leads project delivery for approved investments and other projects and facilitates gating decisions and reporting through governance. This work is guided by an evolving Investment Portfolio and Project Management Framework.

The Management Review, Evaluation and Performance Reporting team leads on the implementation of the Departmental Results Framework, including ensuring the logic model and performance measurement framework accurately reflects the Centre's business model, and that performance measures are sustainable and support intended results. As part of the accountability framework, this Team leads on the development and implementation of the FINTRAC's Risk-Based Management Review and Evaluation Plan and the Corporate Risk Profile. The Team develops the annual Departmental Results Report and the Centre's response to the Management Accountability Framework, and also looks after the Centre's governance including the management of EXCO and Management Advisory Committee (MAC)'s agenda, records of decisions and forward agenda. During her tenure, Director Semaan also participated in the DM-level Small Agency Forum and the Community of Federal Regulators, for which principal support was provided by the Director's Office who would consult with CBPM on substantive questions on specific issues.

Key and Daily Files of CBPM:

Office of the Privacy Commissioner (OPC) audit: The PCMLTFA requires the OPC to conduct biennial privacy audits. The 2019 audit was launched in December 2019 and encountered significant delays as a result of the COVID-19 pandemic. The OPC indicated their intent to provide their preliminary results in early November and, based on preliminary discussions, no major findings are expected and FINTRAC is well positioned to respond to the expected recommendations.

Business Resumption as part of FINTRAC's response to COVID-19 pandemic is supported by a Tiger Team led by CBPM. In addition to supporting the Business Resumption Committee, the Tiger Team works in close collaboration with key functional Office of Primary Interest (OPI) to manage the development and implementation of the multitude of initiatives underway to support the Centre's effort to achieve 100% business resumption.

Future State of the Centre Assessment: In support of sharing advice with Department of Finance and Public Safety on regime direction and tangible steps we can take collectively to improve shared effectiveness, an exercise was initiated to examine the Centre's current operational model in an effort to develop and position the future state for the organization. This exercise is also intended to inform the focus of the Centre's future Budget, and support FINTRAC's input in an Interdepartmental Review exercise lead by the Department of Finance and currently targeted for completion in March/April 2021.

Annual integrated planning will be launched in the coming weeks to support the development of the Departmental Plan, Director's Performance Agreement, Investment Plan, IM/IT Plan (lead by IM/IT sector), Sector Plans and support budget and HR planning activities.

Annual performance results reporting is on target to be launched in Q4 to support the development of the 2020/21Departmental Results Report (DRR), the Director's Performance Assessment, the Annual Report (lead by Communications), the Report to the Minister on Compliance and Related Activities (lead by SPAR). Important to note, while a date has not yet been confirmed, the 2019-20 DRR is expected to be tabled in Parliament this fall.

The Management Accountability Framework is normally launched in the fall. Given the extraordinary circumstances surrounding the COVID-19 pandemic, TBS has modified the assessment approach. However, given our status as a separate agency, and since we do not have transfer payments as part of our funding envelope, there are no indicators applicable to FINTRAC for the 2020-21 MAF cycle. As a result, FINTRAC has been exempted from responding to this year's MAF.

Corporate Risk Profile (CRP) assessment is usually launched in Q2 to support the various planning activities and accountability priorities. To note, due to the pandemic, the revised CRP was not tabled before EXCO for approval last March as planned, as such, this year's exercise will largely be about reviewing and updating the work already done. Governance approval is targeted for this fall.

Quarterly Investment Projects Dashboard is targeted for tabling through governance in November. Of the numerous projects currently being managed, the key projects to watch for due to their complexity and importance to the legislative framework consist of the Legislative and Regulatory Implementation and HQ on the Move. Both of these projects are addressed more fully later in this binder.

5. Security

FINTRAC's Security Unit is led by [REDACTED], Manager and Chief Security Officer, and is comprised of a Security Operations team, IT Security team, and Organizational Security and Program Alignment team. The Security unit is responsible for the safeguarding of employees and the protection of the information, assets and services of Canada's Financial Intelligence Unit, and shares responsibilities in the IT Security domain with IM/IT.

Security is also responsible for the delivery of rigorous security measures that safeguard the Centre's physical premises and IT systems, and include the handling, storage and retention of all personal and other sensitive information under its control. As a condition of employment, employees must undergo an enhanced security screening process, which includes obtaining and maintaining a security clearance at the top secret level along with an enhanced reliability status, including a Law Enforcement Records Check (LERC) and a security interview. They are also trained in their responsibilities involving the protection of personal information and only access sensitive information on a need-to-know basis.

Finally, Security is also responsible for the development and implementation of the Departmental Security Plan (DSP) that provides an integrated view of the security program and outlines how security activities are integrated within the Centre's operations, as well as how they are aligned with organizational priorities. The DSP documents FINTRAC's current security posture, provides objectives and timelines for improving the Centre's current state of security, and demonstrates how the Centre will continue to contribute to and align with broader Government of Canada security priorities.

Teams:

• The Security Operation team, responsible for the Security Operations Centre, NHQ building security and emergency response, regional security, physical security, Communications Security (COMSEC) equipment, and BCP.
• The IT Security team, responsible for IT Security Policy, Security Assessment and Authorization of IT systems, as well as being the Information Systems Security Officer (ISSO) for high-security IT systems.
• The Organizational Security and Program Alignment team, responsible for personnel security screening, security in contracting, security awareness, and the new counter-intelligence/insider threat program being developed.

Key and Daily Files of Security:

• Ensuring the business continuity of the Centre through the management of the COVID-19 response and maximizing building occupancy to enable critical and priority work that can only be delivered on-site.
• Monitoring the conclusion of the Office of the Privacy Commissioner audit currently underway that is widely expected to bring forward recommendations to implement an aggressive active monitoring of data access program which has been identified as an investment priority to be launched this fiscal year, and enhancements to the BCP template to better align with TBS' Directive on Security Management.
• Administering security screening of a larger-than-normal influx of new recruits to accelerate the hiring new resources from Budget 2020 budget increases and addressing existing vacancies.
• Providing security advice supporting the HQ On the Move Project and the Montreal Regional Relocation to ensure forward momentum is maintained, all while respecting the unique security requirements brought about by the Centre's mandate.
• Providing timely IT Security risk management advice on a range of new and legacy systems and initiatives to support the advancement of key projects while maintaining security on existing legacy infrastructure and systems.
• Modernizing security equipment in the current HQ location and in regional offices as they undergo renovations in support of a high-security environment which is a hallmark of an intelligence unit.
• Ensuring the security of, and emergency response for, the Centre's personnel and resources which are clustered on [REDACTED] of a 26-storey building.

6. Communications

FINTRAC's Communications unit is led by Darren Gibb, Manager of Communications, and is comprised of a Communications team, a Publications team and an Access to Information and Privacy (ATIP) team.

Teams:

The Centre's relatively small Communications team (9 personnel) is led by a Team Lead (FT-05) and is responsible for ensuring that FINTRAC adheres to the Government of Canada's Policy on Communications and Federal Identity. In so doing, it undertakes all of the same communications activities that are carried out in larger departments and agencies, including:

• Communications strategy, planning and management of issues in the public environment;
• Regular collaboration with Communications counterparts in Finance Canada, federal regime partners, municipal, provincial and federal police and law enforcement agencies across Canada, reporting entities, stakeholders and international allies;
• Media monitoring (compiling/sharing morning and afternoon clipping packages on weekdays and on an as-needed basis on weekends);
• Media relations (150+ media requests per year);
• Media training (as required);
• Social media management and engagement (300+ Twitter postings per year);
• Responses to pubic inquiries (350+ per year);
• Support to parliamentary affairs (e.g., speeches, QA packages, etc.);
• Development of FINTRAC's public Annual Report (legislative requirement);
• Centre-wide communications support to the Executive Committee and sectors (e.g., writing, editing, design, distribution, photography, promotional material, etc.);
• Centre-wide translation (undertaken by 2 on-site translators from the Translation Bureau);
• Communications support to the Director (e.g., keynote speeches, messages, updating the Director's Corner on the FINTRANET, etc.);
• Support to clients on internal communications for Centre-wide initiatives;
• Management and daily updating of FINTRAC's internal website (the ‘FINTRANET'); and
• Organization of town hall meetings.

FINTRAC's Publication team (1 person) is led by a Team Lead (FT-05) and is responsible for:

• Content management of the Centre's public website;
• Representing FINTRAC at all Government of Canada web-related fora;
• FINTRAC-wide publications support, particularly on major Compliance projects;
• Communications support for IT external-facing projects;
• Ensuring and reporting on the application of TBS directives; and
• Managing copyright and reproduction requests.

FINTRAC's ATIP team (3 personnel) is led by the Centre's ATIP Coordinator (FT-05) and is responsible for ensuring that FINTRAC fulfills its responsibilities under the Access to Information Act and Privacy Act, including:

• Administering and managing ATIP requests (150+ requests per year) through FINTRAC's comprehensive ATIP Network;
• Managing complaints to the Information and Privacy Commissioners (currently 4);
• Providing access to information and privacy expertise, guidance and assessments on Centre-wide issues and projects;
• Coordinating the Proactive Disclosure publication on the Government of Canada's Open Data website;
• Development of FINTRAC's Access to Information and Privacy Act annual reports;
• FINTRAC's annual Info Source publication;
• Management of privacy breaches (last breach was in 2012);
• Support to FINTRAC's Chief Privacy Officer (Annette Ryan);
• Centre-wide awareness and training activities; and
• Represent FINTRAC at the Government of Canada's ATIP Community/Coordinator meetings.

Key and Daily Files of Communications:

The top three priorities for FINTRAC's Communications unit over the coming months are as follows:

• Management of a number of issues and activities that will/may receive attention in the public environment;
• Preparation/support of FINTRAC witnesses (and management of follow-on public interest) in relation to the Commission of Inquiry into Money Laundering in British Columbia (Cullen Commission); and
• The management of ongoing internal communications in relation to the COVID-19 pandemic.

Enterprise Policy, Research and Programs Sector – Financials

People & Culture Sector – Overview

Our Vision

We are a dynamic organization of agile leaders and employees. We strive to provide the best employee work experience by attracting, engaging and developing talent and creating an inclusive culture that drives excellence and innovation.

Our FINTRAC People Management Framework is the foundation to enable our People and Culture vision, Our Talent, Our Future, which in turn enables us to deliver the FINTRAC vision and strategic pillars.

Our people segments are critical for how we recruit, develop and retain our talent: from workforce planning; to learning and development; to performance management; to talent management. Recruiting and retaining top talent is a significant challenge throughout the public service and it is one of our most important priorities at FINTRAC.

Our workplace segments drive how we promote a productive, supportive and healthy work environment: from healthy and inclusive; to workplace management; to classification and organizational design; to total compensation. These HR service offerings and programs are designed to enable the diverse demographics of our employees to excel at FINTRAC.

The glue that strengthens our people and our workplace is our culture, #WEAREFINTRAC, which defines how we work together. This is enhanced by our six People and Culture key areas of focus, which supports the three FINTRAC strategic pillars:

• Promote a culture of accountability: empowerment and change,
• Prepare FINTRAC for the future: continuous growth and modernization, and
• Collaborate to strengthen results: engagement and collaboration.

Executive

Karen Figuerola
CHRO & Assistant Director, People & Culture

Karen Figuerola serves as Chief Human Resources Officer (CHRO) and Assistant Director, People and Culture for the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Canada's financial intelligence unit (FIU). In her current role, Karen is responsible for leading FINTRAC's overall people management strategy, talent acquisition and staffing, leadership development, workplace and workforce safety and well-being, diversity and inclusion, organizational design and classification, compensation and benefits, HR operations, HR reporting and analytics, HR modernization and technology, employee relations, and change management. As a member of FINTRAC's Executive Committee, she leads in reinforcing a strong organizational culture based on the FINTRAC values, creating and leading large-scale employee engagement and development programs, and performance and talent management strategies that support the achievement of business goals and objectives. As CHRO, she leads the Centre's high caliber People & Culture team and has changed the function, culture, and impact of HR across the Centre to support its mandate and strategic priorities as well as the needs and development of its employees across Canada. Karen was named Chief Human Resources Officer for FINTRAC in January 2019.

Prior to FINTRAC, Karen was Director General, HR Operations and Renewal at Public Services and Procurement Canada (PSPC) where she oversaw HR client services and operations, while also providing leadership on HR Analytics, Enterprise Talent Acquisition, Organizational Design & Classification, and HR Renewal. While at PSPC she was also selected to lead an enterprise-wide HR transformation project under the direct leadership of the Deputy Minister.

Karen joined the Public Service in 2004, working as a Project Coordinator and Administrative Assistant in the Labour Program. Having HR as her passion and career of choice, Karen moved into an HR Advisor role in 2006 with primary expertise and focus on staffing, HR planning, HR transformation and workforce strategies. Karen has grown within the HR community and has sought out challenging roles within departments undergoing extensive change and transformation such as Employment and Social Development Canada/Service Canada, Natural Resources Canada, Shared Services Canada, and Correctional Service Canada. She has successfully led large change initiatives within such large public service organizations focused on transforming the business of HR by yielding a strategic, streamlined and value-added function that works in partnership with its clients.

Karen became an executive in 2013 and has continuously endeavored to take on challenging roles centered around transformation and change with the objective of propelling HR as a key value-added business partner.

She is fluently trilingual, speaking English, French and Spanish (her mother-tongue), and holds a Bachelor of Arts Degree from Carleton University with a specialization in Psychology and Organizational Effectiveness.

Sector Organization Chart

Legend

ACT = Acting
ASG-I = Assignment In
ASG-O = Assignment Out
INTER-I = Interchange In
INTER-O = Interchange Out
TERM = Term
( ) = Away from substantive
* = Away from sector
Direct reports :
Functional reports :
[REDACTED]

Overview of Sector Units

Wellness Programs, Compensation & Reporting Unit

Unit responsible for the development and delivery of human resources information systems, production of demographics and other reports and delivery of full spectrum of compensation, EAP, wellness, and OHS services across the Centre.

Future vision: Employing predictive analytics and robust research methodologies to address people challenges, forecast trends, determine linkages/correlation with HR data and develop actionable recommendations to enable stakeholders to make informed decisions.

Centre of Expertise for the following HR programs:

• Compensation and Benefits
• Employee Assistance Program
• Occupational Health and Safety
• Ergonomic Assessment Coordination
• Workplace Wellness (Mental Health)
• Operational responsibility for the HR system (HR Ware)
• Provision of high quality people analytics
• Contribute human resources management analytics and metrics required for corporate reporting

Functional Highlights:

Compensation and Benefits

• Provide accurate and timely compensation advice to employees individually and to management from a corporate perspective
• Monitor service standards for responding to compensation requests and adjust them when necessary
• Research impacts relating to benefits and entitlements
• Ensure accurate calculation and payments of the Performance Pay awards
• Active engagement and participation in HR to Pay governance and activities
• Undertake and report on active contributions to HR-to-pay stabilization to ensure employees are paid accurately and on time including tracking of timeliness of human resources transactions leading to a pay action

Wellness Programs & OHS

• Promote through timely and informative communications to employees the value of the following programs: Occupational Health & Safety Program; Employee Assistance Program; GoodLife Corporate Membership
• Provide tools and resources to support employees and managers
• Ensure that FINTRAC align with the legislative requirements related to Health & Safety (playing a critical role in the Centre's response to the pandemic)

Analytics and Reporting

• HR System replacement
• Monitoring of system to ensure data integrity and ensure that corrections are done for erroneous data
• Responsible for the output of Organizational charts on the Fintranet
• Produce the HR demographics documents for the Centre and each Sector/Directorate
• Prepare data for Annual Reports
• Build Ad Hoc Reports for clients and HR colleagues to respond to queries

Current key files and priorities:

OHS – COVID-19: Ongoing

• Enterprise approach to Centre Health & Capacity reporting in relation to COVID-19 to support senior management decision-making & reporting to TBS-OCHRO
• Administers the Occupational Health & Safety program, including providing advice/guidance relating to COVID-19, and managing and tracking COVID-19-related scenarios
• Work closely with the Occupational Health and Safety committee
• Effective and timely guidance, direction, application and reporting of 699 Leave usage across the Centre
• Provides support to managers and employees during the pandemic (health and safety and mental health resources)
• Developed and implemented the Safe at Work Playbook including Personas
• Established a number of protocols to ensure the safety and security in the workplace and held three information sessions with 99 registered
• Implemented a contact tracing application housed on the FINTRANET that all on-site personnel are required to complete on a daily basis
• Developed a Manager's Toolkit with accompanying FAQs for the COVID-19 pandemic
• Led six virtual Manager's Forums to keep management community apprised of the various protocols, temporary policies and guidance on managing during the pandemic
• Played a key role in the development and launch of the Pulse Check Survey, participation in the analysis of the results and action plan
• Implemented an approach to equipping employees who are working remotely with enhanced peripherals and ergonomic chairs
• Meets regularly with central agencies and other departments across the GC to obtain guidance and share best practices

HR Programs and Policy (HRPP) Unit

FINTRAC, considered a separate employer, falls under Schedule V of the Financial Administration Act and operates under the HR authorities provided to the Director/CEO of FINTRAC under the PCMLTFA. As a result of this status and also the fact that FINTRAC operates in a non-unionized environment, P&C's HR Programs and Policies Unit plays an integral role in the Centre as it leads the development and delivery of the core human resources programs, initiatives and policies across the Centre.

Vision: Enabling a high-performing and adaptable workforce through innovative, inclusive and flexible people programs and policies.

The HR Programs and Policies is comprised of high-performing individuals who contribute to the FINTRAC's mandate by delivering a wide range of people management HR policy services and programs within the Centre. HRPP is responsible for program services as well as policy guidance and development within eight (8) main functions:

• Organisational design and classification;
• HR planning and corporate staffing;
• Official languages;
• Executive and non-executive performance management;
• Executive talent management;
• Employment equity, diversity and inclusion;
• Labour relations;
• Workplace relations (Code of conduct, Values and Ethics, COVID 19 leave and usage, Terms and conditions, Prevention of harassment and violence in the workplace).

Current key files and priorities:

Bill C-65 Implementation Strategy: January 2021

• Bill C-65 will amend Part II of the Canada Labour Code to include specific measures for employers to follow in the prevention and resolution of violence and harassment in the workplace.
• These changes will apply to the entire Federal public service and will come into force on January 1, 2021. These legislative changes will further re-inforce the Centre's zero tolerance approach to violence and harassment in the workplace.
• Work is currently underway to update the Centre's Policy on the Prevention and Resolution of Conflict and Harassment to reflect the upcoming legislative changes as well as to implement the other requirements. 
• In addition, harassment and violence prevention training will be rolled-out in the new year to all employees and managers.
• Further information will also be disseminated when the revised policy takes effect, so that employees and managers are aware of the procedures that will be in place to respond to incidents of harassment and violence, should they occur.

Year 1 of the People Management Renewal: Phased Approach

The current people management suite provides the Centre with foundational support in developing and sustaining a high-performing workforce that ensures good governance and service to Canadians, and an inclusive, safe, barrier-free workplace that embodies public service values including respect for people, respect for democracy, integrity, stewardship and excellence in its actions and decisions.

Human Resources Policies:

• Code of Conduct, Values and Ethics
• Directive on Second Language Training
• FINTRAC FlexWork, Leave, and Overtime Directive
• Learning and Development Policy
• Occupational Health and Safety General Policy Statement
• Occupational Health and Safety Policy
• Policy on Membership Fees
• Policy on the Prevention and Resolution of Conflict and Harassment
• Political Activities: Rights and Responsibilities of Employees
• Staffing Policy
• Delegation Instrument for Human Resources

Extensive work is under way to modernize and renew our People Management Policy framework and policies with the purpose of ensuring the Centre has the right policies, tools and procedures in place to ensure an effective and efficient management of Human Resources.

Current focus:

• Modernize and up-date of the staffing Policy/directive
• Development of interchange assignment guidelines
• Development of area of selection guidelines
• Development of staffing options guidelines
• Modernization and establishment of FINTRAC Values Statement
• Update FINTRAC's Code of Conduct and Values and Ethics
• Year 1 of the updates Update of FINTRAC's Terms and Conditions of Employment

COVID 19 leave strategy and reporting: Ongoing

The leave code 699 (Other Paid Leave) is intended to account for time (full or partial days) when employees are unable to work for COVID-related reasons. FINTRAC'S COVID-19 approach has been developed to ensure that employees who are affected and unable to work due to the pandemic are given appropriate consideration, while aligning with the Core Public Administration and Treasury Board Secretariat.

People and Culture continues to adjust COVID-19 direction, policies and tools as necessary based on the evolution of the situation and the governments' response to the pandemic.

P&C has not updated/issued new guidance on 699 as per overall direction from TBS.

Update of the Performance Management Guide: End of 2020-21

The Performance Management Program is designed to encourage excellence in performance by recognizing and rewarding the achievement of results that are linked to FINTRAC business priorities and realized in a manner that is consistent with our leadership competencies and values. The Performance Management Program follows an annual cycle, with a review period spanning April 1st to March 31st of each year.

FINTRAC offers Performance Pay and occurs once per year, at fiscal year-end upon completion of formal performance agreements and reviews.

Year 1 of the Development and Establishment of Executive Talent Management Foundational Framework and Process: Talent Management Day, November 6, 2020

Talent management is critical for how we recruit, develop and retain our talent: from workforce planning; to learning and development; to performance management; to career management. Recruiting and retaining top talent is a significant challenge throughout the public service and it is one of our most important priorities at FINTRAC. The Centre must capitalize on its unique status to modernize and create an innovative and optimized talent management approach, to enable the hiring of top talent and meet our objective of a high-performing workforce. It is all about building and sustaining excellence in the Centre, by maximizing the contribution and realizing the potential of every individual in order to meet organizational priorities. Focusing on talent management is particularly important now because of current and forecasted workforce and workplace changes, such as:

• The changing nature of our work and ongoing transformations mean we need to start identifying and developing future competencies.
• We are seeing different expectations from a multigenerational workforce that need to be anticipated and leveraged.
• Impending retirements and ‘age bunching' (where expected successors are retiring at or about the same time as individuals they would naturally replace) are critical issues in certain areas of the Centre.

To this end, a talent management pilot initiative was approved by the Executive Committee in the Fall of 2019, to be launched in the 2020-21 fiscal year. The pilot will first focus on Director-level positions and above and will eventually be increased in phases until all employees in the organization become participants of an integrated performance management and talent management program.

Update of the HR Instrument of Delegations: Ongoing

Review and update HR instrument of delegation with Direction from incoming Director

Key Corporate People Management Reporting: Ongoing / Completed

• Update of the Official Languages Action Plan
• 2019 Official Languages Statistical Report
• 2019 Employment Equity Report
• 2019 Multiculturalism Report
• Update of the Employment Equity, Diversity and Inclusion Action Plan
• Support to Corporate Reporting

HR Business Partner Services & Talent Acquisition Strategies Unit

Vision: Recognized as a value-added and trusted HR business partner and service provider to FINTRAC employees and managers, categorized by our commitment to service excellence, fairness and quality.

Home of the HR Business Partners! Dedicated HR Business Partners for Sector management teams to provide strategic guidance and support in their day to day people management needs.

Talent Acquisition is synonymous with recruitment however with much more depth than the traditional approach. In this model, the HR partner does not solely provide advice or strategies on "how to staff" but rather compliments it with research on labour markets' trends; public and private sector job advertisements, new competencies, targeted recruitment, etc.

Coming Soon! Future Home of HR Hub! Focal point for all FINTRAC employees for all general HR inquiries:

• General HR information
• Guidance surrounding HR programs, policies and procedures
• On-boarding and Off-Boarding

Strategic HR Business Partner Model and Vision

1. Talent Acquisition (TA) & Retention: Talent Acquisition is synonymous with recruitment however with much more depth than the traditional approach. In this model, the HR partner does not solely provide advice or strategies on "how to staff" but rather compliments it with research on labour markets' trends; public and private sector job advertisements, new competencies, targeted recruitment, etc. In essence, based on data and supported research, the HR partner assumes a more proactive role by using the information to define and develop the recruitment strategy for all group and levels of the organization. The goal is to use the information and adjust the recruitment strategy.
2. Performance Measurement (PM) and Talent Management (TM): Following Talent Acquisition, Performance Measurement focuses on how the workforce is performing and its ability to meet the business needs/priorities. PM includes the employees’ performance but also determines the units’ ability to achieve their business objectives. As such, the information can assist with reviewing the quality of talent; focus on fit-gap analysis; address labour relations and performance situations, adjust the recruitment strategy; develop a targeted learning and development plan, and identifying top talent. As such, once the top talent is identified, the information is used for retention, succession and career planning.
3. Workplace and Workforce Wellness: Unlike PM and TM, Workplace and workforce wellness does not focus solely on performance but rather on the team's mental health and well-being in the workplace. It focuses on measuring engagement, motivation, work-life balance, etc. It is measured through indicators provided by the PSES, Pulse checks, leave with or without pay trends, formal/informal complaints environmental scans, etc. This provides the HR partners and clients with an additional layer of information to objectively assess and understand their workforce and workplace.
4. Creative Solutions: The creative solutions component analyses the information from all three pillars to provide an integrated, comprehensive and strategic plan. The HR partner can provide recommendations based on the information such as organization design solutions, training, project management, etc. This component focuses on tailored solutions to the clients' business context. It also serves to measure the return on investment and value HR provides to clients.

Current key files and priorities:

Talent Acquisition & Staffing – to date: Completed

• While navigating and adapting to the challenges of the pandemic, Managers along with their colleagues in P&C have been hard at work trying to fill many positions within the Centre.
• Following the success of three Recruitment Open Houses as well as via other external staffing processes, I am pleased to highlight that we have hired 62 new employees since the month of January 2020. Of these 62 hires, 33 occurred since April 2020.
• As a Centre we remain committed to student and youth employment and have offered 60 students meaningful work terms so far this year.
• In parallel, P&C and managers are committed to continuous growth and development of our talented FINTRAC workforce. Since January 2020, 81 FINTRAC employees have been mobilized to fill current vacancies and opportunities, and of these 27 were promotions.

Talent Acquisition & Staffing – On the Horizon

• Preparing Vacancy Management for Q4 and aligning business needs with salary forecast per Sector – Ongoing
• Further operationalization of the Talent Acquisition Framework – Ongoing
  • Developing Recruitment Ambassador concept and pilot of new assessment approaches
• Student Program & Outreach
  • Coordination of the new hires and rehires for each Sector – Fall/Winter terms 2020-21
  • Planning virtual approach for Student Outreach – April 2021
• Planning for the virtual Federal Safety and Security Intelligence Fair – Tentatively January 2021
  • Planning stages for new approach to this yearly Career Fair along with partners in the Security Portfolio
• Review of tools and business processes to adapt to remote work environment – Ongoing

Enterprise Talent Acquisition Framework: Phased Approach

• In May 2020, P&C launched its Enterprise Talent Acquisition (ETA) Framework to modernise our approach to recruitment and leverage best practices and technology to create efficiencies.
• The ETA aligns with FINTRAC's Strategic Pillars, the People and Culture Vision and helps position the Centre to deliver on its mandate.
• The ETA brings together three key elements that will enable Sectors to fill vacancies: Strategic Analysis of Business Needs; Employer Branding along with Enhanced candidate experience and Focused Outreach and Agile Recruitment leveraging existing technology/platforms.
• FINTRAC will continue to recruit and grow high calibre candidates to meet the current and future business needs.

Employee Engagement, Change Management & Enterprise Learning (EECMEL) Unit

Oversees the programs and services across the enterprise that drive employee engagement, continuous employee growth and development as well as awards and recognition while supporting the culture and change agenda within FINTRAC.

• Onboarding and Off-Boarding Programs (incl. Exit Interviews)
• Awards and Recognition
• PSES
• Change Management: HQ On the Move
• Change Management: Business Resumption and COVID Change Agent
• Learning Strategy, Policy and Program
• Learning and Development: Corporate Training and Programs (collaboration w/HRPP Unit given the link to Talent Management)
• Leadership Development
• Learning Curriculums and Mandatory Training
• Operations of Mobility and Development Programs (e.g., Exchange Program)
• FINTRAC Long Service Awards Coordination

Current key files and priorities:

Change Management & Culture: Ongoing

P&C is responsible for implementing and leading Change Management (CM) at FINTRAC

As part of the new 2019-2024 People and Culture Strategy – Our Talent, Our Vision, change management is one of our key areas of focus to ‘enabling enterprise agility through effective change leadership and enduring change resilience', including:

• Develop a proactive workforce of innovators and collaborators that embrace change, while ensuring a flexible, responsive and adaptive organization that is committed to continuous improvement and new ideas.
• Create a change management framework and integrate change management best practices into the way we work.
• Build enterprise-wide change management capacity including change resilience and change leadership organizational capabilities.

The CHRO is the Co-Chair of FINTRAC's Culture and Change Sub-Committee. As part of FINTRAC's governance, this Sub-Committee supports MAC in fulfilling its mandate by:

• Enabling FINTRAC to deliver a consistent and effective change and culture strategy across the Centre to drive, support and maintain a healthy and effective workplace;
• Focussing on building a true organizational learning culture anchored by a skilled and engaged workforce; and
• Recommending priorities, strategies, areas for investments, and areas for evaluation to continue to strengthen a higher performing culture founded on our values, ethics and wellness

HQ On the Move – Change Management: Ongoing

FINTRAC HQ is moving in 2025 and change management considerations include:

• Moving staff to a new location, especially out of the downtown Core, while proactively managing the risk of increased attrition due to the move
• Moving to unassigned seating (activity-based workspace), as much as operationally feasible given the number of Special Purpose Spaces (SPS) required

P&C co-leads the HQ on the Move Change Agent Network (CAN)

• Each sector has identified a change agent representative who will support and promote change management activities in their sector
• The CAN kicked off in January 2020, followed by a Stakeholder Impact Analysis workshop with CAN members
• Currently building a strategy to leverage this network throughout the HQ on the Move project

Leveraging GCworkplace tools and resources provided by PSPC, along with demonstrating the FINTRAC Change Management Workbook in practice, P&C is working with Communications to define change management and communications deliverables, such as:

• Planned communications to staff;
• General information about the new site;
• Potential site visits (in person or virtual) to the new location;
• Potential visits (in person or virtual) to an already established activity-based workspace;
• Videos and other information on activity-based space;
• Information about the new location, etc.

Pubic Service Employee Survey (PSES) 2019: Ongoing

• Final results were received in January 2020 and were communicated to staff
• PSES Working Group initiated work on the Action Plan revision however, COVID paused PSES activities – until now
• With a fresh look at the file, it is has provided us with the opportunity to reconsider our approach to the Action Plan
• The PSES leads looked carefully at the PSES results and realized that the Workplace Assessment recommendations, Ombudsman's feedback and on-going exit interview results were very relevant to the PSES findings
• As a result, it was determined that these four sources of information were also important to create a fulsome action plan
• Moving forward, the PSES Working Group will work with the sectors to review the recommendations from these various sources and revise the Action Plan accordingly
• As the Action Plan is now based on a more fulsome set of inputs and recommendations, it was decided to rebrand the PSES Action Plan
• The new name of the Action Plan will be the "Workplace Wellness and Culture Action Plan", or WWCAP
• A communication approach to all staff regarding the WWCAP will be developed and an all staff update sent in the next few weeks

Enterprise Learning and Leadership Development: Ongoing

As part of a commitment in the 2017 PSES Action Plan, P&C began reviewing FINTRAC's enterprise learning structure and governance as well as completed a gap analysis exercise.

EECMEL is exploring various elements to enhance our learning role at the Centre, including:

• Developing an approach to identify and report on mandatory training across the Centre
• Developing standardized guidance for Sectors who have a training functions
• Exploring standardization in developing training expertise at the Centre
• Co-piloting design tools at the Centre to develop our own interactive, self-directed learning
• Supporting initiatives related to the modernization of the Center's learning management system capacity
• Exploring in-house training options for official languages training

At P&C we are very excited about some developments in the world of enterprise learning and leadership development, specifically in the areas of Authority Delegation Training, Leadership Training and Positive Space Training

• Authority delegation training:
  • ADT training targets all supervisors and managers with a financial delegation and their actors
  • We are happy to report 100% compliance with the CSPS portion of the authority delegation training
  • Now P&C is working on developing FINTRAC specific HR ADT content in the form of a self-directed learning module
  • This will be followed by a virtual or in-person session covering Finance and HR elements that are specific to FINTRAC and will be in place by the end of the fiscal year
• Leadership Training – EECMEL is currently working to enhance FINTRAC's leadership development through the following initiatives:
  • Character Leadership (CL): leveraging the expertise of the Canada Revenue Agency, EECMEL is organizing an agency manager's meeting where CRA will present the CL model as part of this year's awareness activities related to character. 
  • EECMEL is also exploring embedding character into other corporate trainings i.e. onboarding as well as organizing an EXCO workshop on leadership character.
  • Leadership Self-Directed Learning Module: EECMEL is developing a self-directed learning module on leadership character that will be available to leaders at all levels of the organization. It will be linked to the Authority Delegation Training – FINTRAC specific module and be recommended training for all leaders with authority delegation.
• Positive Space Training:
  • P&C, with the endorsement of our diversity champion Liz Yong and with support from our Ombudsman Mijanoux Beauchamp, has partnered with the Pride@IRCC network from Immigration, Refugees and Citizenship Canada
  • Over the last few years, Pride@IRCC has developed and implemented a robust positive space training program
  • The training purpose, aimed at all staff, is to help create a positive and inclusive space for all employees, and particularly those who are gender diverse
  • Pride@IRCC has graciously agreed to facilitate 3 virtual sessions for our staff in December
  • Next fiscal they will also offer spaces to our interested staff who would like to become a Positive Space Ambassador who want to build their own awareness of gender diversity and inclusivity, help our staff with support services or by becoming Positive Space Trainers themselves

Employee Engagement: Ongoing

• P&C leads an employee engagement function at the Centre.
• This function includes such files as awards and recognition, communications on HR issues and initiatives, action plans related to PSES and other inputs, and managing enterprise wide functions such as National Public Service Week.

Awards and Recognition: November 2020

• Review of Formal Awards nominations at EXCO to be scheduled for November 4, 2020
• Virtual Awards Ceremony being planned for the last week of November

Conclusion

As your trusted HR Business strategist, engineer and enabler, P&C and the CHRO are focused on:

• Structuring HR to align with the clients business strategy, deliver effective services and strategic insights to the business;
• Using human capital analytics by connecting systems or partnering with different resources for gathering data and developing insights to drive decision making;
• Enhancing employee experience details HR's focus and steps for building employee-engaging programs and initiatives;
• Building HR's strategic capacity is developing mindsets, skills, and competencies necessary for mobilizing efforts to align to FINTRAC priorities and successfully navigating the 21st-century business terrain.
• Measuring success

People & Culture Sector – Financials

Information Management and Information Technology - Sector Overview

Introduction

As Canada's financial intelligence unit, an integral player within the Anti-Money Laundering and Anti-Terrorist Financing Regime, FINTRAC's goal is to contribute to the safety of Canadians and the security of the economy as a trusted leader in the global fight against money laundering and terrorist activity financing.

The role of IM/IT is to be a key partner in positioning FINTRAC to fulfill its mandate. As the bad actors find increasingly sophisticated methods to avoid detection, FINTRAC must keep pace by re-evaluating its processes and systems. Maintaining and advancing the capabilities FINTRAC employs in carrying out this important work is imperative and a priority for IM/IT. In support of this, we are committed to developing a modern digital strategy to help build a modernized FINTRAC of the future.

Executive

Rachel Porteous
Chief Information Officer

Rachel Porteous is a distinguished Senior Executive with over 30 years of IM/IT experience; proven track record of successes in developing solutions that improve the efficiency and effectiveness of IT and business operations. Strong leader able to drive transformations and service delivery while developing high performing teams. Rachel has been the Chief Information Officer at FINTRAC since January of 2019. She was the Chief Information Officer and Director General of the Solutions and Information Management Branch at Immigration, Refugees and Citizenship Canada (IRCC) from 2017 to 2019. Prior to IRCC, Rachel occupied the position of Director General/Chief Technology Officer at Public Services and Procurement Canada where she was responsible to lead the advancements in Enterprise Architecture and Innovation, IT Security and Product Management.

Rachel has extensive experience in leading and supporting the development and implementation of Departmental IT products and programs, as well as multiple multimillion-dollar projects across many departments. As the Executive Director and Acting Director General of Enterprise Services at Canada Border Services Agency (CBSA) and the Director of Information Management and Enterprise Resourcing Planning Systems at the Communications Security Establishment (CSE), Rachel has developed, led and maintained consultative and collaborative partnerships, networks and projects. She started her career at Indian and Northern Affairs Department where she excelled in multiple IM/IT positions over 17 years.

Rachel holds a Bachelor of Applied Science, with a Major in Computer Science from the Université du Québec en Outaouais. She is a mother of two daughters and volunteers in two non-for-profit organizations, the Association of Public Sector Information Professionals (DPI) and the CIO Association of Canada.

Sector Organization Chart

Legend

ACT = Acting
ASG-I = Assignment In
ASG-O = Assignment Out
INTER-I = Interchange In
INTER-O = Interchange Out
TERM = Term
( ) = Away from substantive
* = Away from sector
Direct reports :
Functional reports :
[REDACTED]

Overview of Sector Units

IT Technical Security and Operational Services

Service Desk

• The hub of IT and responsible for triaging and managing all service management requests. It triages on average more than 15,000 tickets per year. It is responsible for computer and office setup, configuring mobile devices, and providing general first-level IT support.

IM/IT Change Management

• Responsible for reviewing, approving, and tracking all production system changes. It ensures proper process and procedures are followed for all production changes. It communicates with both IT Management and client stakeholders of upcoming changes. It also ensures that requests are vetted and backup plans are in place.

Technical Security Services

• Accountable for technical security architecture, design, implementation, testing and monitoring. It works closely with ITSOS as they are involved in almost every aspect of FINTRAC's technical systems. From evaluations through to production monitoring, TSS play a key role in ensuring that FINTRAC's system are monitored and as secure as possible.

Infrastructure Operations

• Responsible for monitoring and managing all of FINTRAC's key production systems. It performs both infrastructure and software installations (middleware, virtual technology, desktop images). It is also responsible for the monitoring and resolution of production systems. One member of this group is on call 24/7 for emergency production issues.

Application Release Management

• Responsible for configuring and deploying systems through FINTRAC's various support environments including production. It is responsible for migrating and deploying applications from the development environment to the test, user acceptance, training, pre-production and production environments. It also ensures that proper best practices are followed while managing the yearly application release schedule.

Solution Services

Application Development

• Constructs, integrates and configures professional business software solutions leveraging a combination of custom code and off the shelf products. The team consists of highly skilled full-stack developers with an analytical mindset who focus on delivering applications to meet FINTRAC business needs.

Quality Assurance Services

• Provides testing services to business sectors. The team is engaged from the start to the end of the project life cycle and is responsible for creating the overall project test plan, executing the plan and managing all the test activities to ensure that the solutions provided meet the business requirements and adhere to FINTRAC's quality standards.

Information and Data Management Services

Business Intelligence Services

• Supports FINTRAC's sectors for business operations, including providing data collection services and aggregating data to develop reports understandable to non-technical users. The team is also responsible for data mining, Cognos maintenance, SQL scripting, data catalogues, reporting and dashboards for data analytics.

Data Management Services

• Responsible for all data ingestion, transformation, logic models and structured storage in our databases to ensure the integrity of data. This team works hand in hand with the Application Development team for software updates and releases. The team's tasks include database and table maintenance, creation/monitoring and Oracle ETL development and maintenance, data loads/integrity/load balancing, data architecture, upgrades and migration of data, HPUX/LINUX and research and development.

Information Management

• Responsible for FINTRAC's Information Management strategy. This team provides training and awareness on IM and record keeping best practices. It ensures alignment with Central Agencies while also following organizational priorities. Its focus is to ensure information is managed as an asset and maintained throughout its lifecycle. Its tasks include IM policy, processes and standards development, IM governance, retention and disposition, Open Government portal, MAF reporting, IM DMS tools, collaboration tools, ATIP support, information security functions, and strategic planning for the IM program.

Web Services

• Responsible for web architecture and design. This includes managing publications for both the FINTRAC internet and INTRANET sites. Some of the activities include support for the web tools and web infrastructure (Drupal). This team works closely with a wide variety of internal clients (Communications, Compliance, etc.) to provide web applications and publishing of documents on FINTRAC's public website as part of our mandated guidance to reporting entities.

Digital Enablement and Enterprise Architecture

Responsible for the development of the IM/IT strategy, which will focus on moving FINTRAC towards an optimized digital environment. Also responsible for enterprise architecture, with the goal of aligning FINTRAC's functions, processes and information systems, with its business goals and strategic direction.

Planning and Governance

Responsible for portfolio management and IT governance structures. Also responsible for crafting and maintaining IT policies and processes. Provides oversight for cost and budget management and acts as the coordinating hub for all IM/IT staffing actions. It is also responsible for corporate reporting and performance measurement, such as the MAF and other TBS/SSC reports. Finally, this unit ensures communication between the CIO's office and staff and updates IM/IT's FINTRANET content.

IM/IT Sector – Financials

C. Key Issues and Files

Commission of Inquiry into Money Laundering in British Columbia (Cullen Commission)

Issue:

FINTRAC's participation in the British Columbia Public Inquiry on Money Laundering.

Background:

Announced in May 2019, by B.C. Premier John Horgan, the Commission has the mandate to study the many typologies of ML in BC, the effectiveness of AML regime bodies, and make recommendations to address conditions which have enabled money laundering to grow in BC. The decision to proceed with a commission of inquiry following the publishing of what are commonly referred to as the German and Maloney independent reviews, which found extraordinary levels of money laundering in B.C.'s real estate market, casinos and other sectors of the economy. The Commission of Inquiry began with opening statements by participants at which Justice Canada gave a consolidated statement on behalf of all federal regime partners. Additional hearings in May-June 2020 consulted subject matter experts regarding ML typologies and trends. The primary hearings involving federal Commission participants will occur from October 2020 to April 2021, followed by the drafting of a final report in 2021. An interim report is expected sometime in late 2020.

Current Status:

FINTRAC is observing and actively participating in the Commission to add value to its information collection and to leverage lessons learned as applicable. FINTRAC has provided the Commission with a 101 overview of the Centre's mandate and has provided a substantial number of documents covering the work FINTRAC has done related to Compliance with the PCMLTFA, strategic intelligence research and financial intelligence analysis.

Considerations:

The Government of Canada must remain aware of Constitutional limitations due to the Commission being a provincial inquiry. When responding to requests for documents, FINTRAC also must remain vigilant regarding statutory limitations prohibiting the sharing of certain information due to provisions in the PCMLTFA.

Next Steps:

FINTRAC SPAR and Communications units are working together on an overarching Communications Strategy to highlight the work FINTRAC has been doing in BC. This includes preparing potential witnesses regarding key issues in order to best aid the commission in its work. While FINTRAC does not expect to appear at a Commission hearing before the "government response" segment in March, FINTRAC deputy directors will be meeting directly with the Commission in November to discuss topics including virtual assets, law enforcement, and real estate. FINTRAC will also continue to respond to the Commission's requests for documents as comprehensively as possible within the limitations of the PCMLTFA.

Business Information and Analytical Modernization System

Issue:

FINTRAC has been working to upgrade its analytical systems over the past several years. A contract with an outside vendor that was part of these efforts ended on December 31, 2019.

Background:

FINTRAC has been working to upgrade its analytical systems over the past several years. A contract with an outside vendor that was part of these efforts ended on December 31, 2019.

Through this contract, FINTRAC has been able to capture and refine its complex intelligence requirements, identify key business processes to streamline, and implement foundational components in support of the ongoing modernization of its analytical systems.

[REDACTED]

[REDACTED]

FINTRAC cannot provide specific details on the contract publicly as the work relates to its analytical systems, which manage the analysis and disclosure of extremely sensitive police, law enforcement and national security intelligence. Given the environment in which FINTRAC works to combat terrorism and money laundering, including by organized crime groups, the protection of its analytical systems is essential.

Current Status:

FINTRAC remains focused on the modernization of its analytical systems in order to keep pace with the rapid technological innovation that is taking place in the financial sector and all sectors around the world.

Considerations:

FINTRAC cannot provide specific details on the contract as the work relates to its analytical systems, which manage the analysis and disclosure of extremely sensitive police, law enforcement and national security intelligence. Given the environment in which FINTRAC works to combat terrorism and money laundering, including by organized crime groups, the protection of its analytical systems is essential.

Next Steps:

As part of the digital strategy, the core business pillar will address future products of the modernization of our analytical system and speed up core business through digital automation and advanced analytics.

Budget 2020 and July Economic and Fiscal Update

Issue:

To provide a summary of funding FINTRAC received in the 2020-21 fiscal year.

Background:

The Government of Canada's Economic and Fiscal Update 2020, presented to the House of Commons on July 8, confirmed funding for FINTRAC, which consists of:

• [REDACTED]
• [REDACTED] ongoing to support FINTRAC's Headquarters relocation; and
• [REDACTED] ongoing for FINTRAC initiatives to strengthen Canada's AML/ATF Regime. Initiatives funded include the issuance of FINTRAC Geographic Advisories; and update systems to enable FINTRAC to receive electronic cross-border currency reports directly from the Canada Border Services Agency (CBSA).

Current Status:

[REDACTED]

Next Steps:

FINTRAC's Finance and Administration team is working with Treasury Board Secretariat of Canada and the Department of Finance Canada to receive the approved funds. With the funds obtained, FINTRAC will begin the necessary hiring processes for the full-time employees identified in the funding, and begin operationalizing the initiatives supported by the funding.

HQ on the Move

Issue:

HQ on the Move relocation project

Background:

FINTRAC has been informed by PSPC that it will be required to vacate its current headquarters location when its lease expires in August 2025, with no possibility of renewal. Since this notification, FINTRAC has been working closely with PSPC Real Property to identify a new home in the National Capital Region (NCR) with FINTRAC's unique security & intelligence (S&I) requirements. FINTRAC's headquarters at 234 Laurier Ave W will be relocated to [REDACTED].

As a fully reimbursing client of PSPC, FINTRAC was responsible for securing the funding for this relocation. FINTRAC submitted a request for funding to the Department of Finance, [REDACTED].

Along with current working groups, an inter-departmental Governance Committee (DG Steering Committee and Senior Project Advisory Committee (SPAC)) is being mobilized with representation from PSPC, FINTRAC and SSC.

Current Status:

The project is currently working with PSPC to validate our security and operational requirements through a functional program exercise resulting in floor by floor concept plans to be completed by end of Dec 2020.

Considerations:

• Adopting GC Workplace Design standards and principles, and additional Change Management and Communications with the agency.
• Future Security profile will accommodate for a hybrid security model allowing operational, security and a high security zone.
• Working with PSPC to validate critical path in order to meet relocation expectations of vacating 234 Laurier Ave by August 2025.
• PSPC is currently in process of amending Prime Consultants SRCL to level II Secret. Previously during tender, SRCL was at Reliability when no tenant was identified.
• The funding approved by TBS is under a Special Purpose Allotment
• FINTRAC Data Centres (Protected B and Secret) moving to SSC End State. This is being handled under the Data Centre Transformation Project.
• There is currently a funding risk to the Data Centre Transformation, Plan A looking towards workload migration (WLM) funding from SSC. SSC has asked for a Plan B funding scenario as contingency. Funding source for Plan B unknown at this time.
• Project will need to seek reprofile of approved funding. Further analysis required in Q3/early Q4 this FY.

Next Steps:

• Concept & Design planning Completed by Q2 FY 2021/22
• Detailed schematic Design Completed by Q1 FY 2022/23
• Construction Tender to Begin Q2 FY 2022/23
• Construction and fit-up to Begin Q1 FY2023/24
• Construction and fit-up Completed, Hand over Building Q4 FY 2024/25
• Begin Transitioning Systems and Organization to New Office Q1 FY 2025/26
• Accreditation, Certifications and Approval to Operate Q2 FY 2025/26
• Fully Operational August 2025.

Implementation of Regulatory Amendments

Issue:

On June 1, 2021, an extensive set of regulatory amendments will come into force that will create or change obligations for reporting entities (REs) that are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). The implementation of these amendments involves all FINTRAC sectors, with the greater impact on Compliance, Information Management /Information Technology (IM/IT) and Enterprise Policy, Research and Programs (EPRP).

Background:

Part of these regulatory amendments came into force on June 1, 2020 and included the registration of new REs: foreign money services businesses and virtual currency (VC) dealers. However, the majority of the regulatory amendments come into force on June 1, 2021 and include the following examples:

• Submission by all REs of Large Virtual Currency Transaction Reports (LVCTRs) to FINTRAC;
• Prepaid payment products and accounts obligations for financial entities (FEs);
• Beneficial ownership obligations extended to all REs;
• Politically exposed persons obligations extended to all REs; and
• Changes to Reporting Schedules.

The implementation of these regulatory amendments was initiated in the Fall of 2019 and involves the development and update of guidance to REs published on FINTRAC's website, as well as extensive IM/IT systems changes for both FINTRAC and REs. Although the majority of amendments will come into force on June 1, 2021, changes to FINTRAC's current reporting forms will be completed past that date.

Prior to the outbreak of COVID-19, FINTRAC and REs were already facing challenges in meeting aggressive timelines to implement all regulatory amendments by June 2021. From the onset of the pandemic until now, FINTRAC IT developers have not been able to remotely access the network, which has delayed the progression of the implementation. Workarounds and innovative approaches were developed as interim solutions, but have created additional work on for Compliance and IM/IT that was not initially planned.

Current Status:

The development and update of guidance are ongoing and about half of the 60 pieces have been drafted to date. Extensive consultations with all RE sectors on these draft guidance pieces are also underway. FINTRAC hopes to publish the majority of these pieces before June 1, 2021, for the exception of the reporting guidance. However, to meet that goal and because of limited resources, the process leading up to their publication needs to be further streamlined.

In light of the issues raised by REs during the last months, combined with the impact of the pandemic on both FINTRAC and REs, the Centre, in consultation with the Department of Finance Canada, has decided to exercise administrative flexibility when assessing and enforcing certain obligations under the Regulations. These flexible administrative measures will remain in effect until updates to the current reporting forms have been implemented by FINTRAC.

Considerations:

FINTRAC's employees working on this non-discretionary priority are often the same that are contributing to the development and implementation of many other non-discretionary policy initiatives and daily operations. These employees are therefore heavily strained and being pushed to the limit. Given this, [REDACTED]. This is compounded by the looming risks associated with the second COVID outbreak that may further reduce the availability of these critical employees. [REDACTED].

Next Steps:

• Options to further streamline the process leading up to the publication of guidance are being developed and will be presented to senior management in the near future.
• A Notice to REs on flexible administrative measures has been drafted and will be published on FINTRAC's website by the middle of November.
• The updated roll-out plan for the updates to existing reporting forms and systems, will also be shared, within the next few weeks, with REs to allow them to make planning and investment decisions.
• FINTRAC will continue to sensitize the Department of Finance Canada on the resource pressures it faces and any emerging issues.