Presentations - Inaugural Conference with Financial Institutions

Examples of AML Program Controls for Cannabis Entities

ML program controls for cannabis entities should consist of a tailored combination of the following elements :

Enhanced due diligence review for all MRBs (i.e., producers and distributors) at onboarding and periodically thereafter, or upon trigger events, and on ancillary businesses based on a number of risk factors such as proximity to the cannabis industry; including a review of:

 Licensing, independent reports and additional information available through Health Canada, which lists violations for various companies

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Relevant adverse information

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Account activity reviews

Ongoing screening of all client records and transactions to identify illegal cannabis-related transactions

Tailored enhanced transaction monitoring on MRBs and primary ancillary businesses for cash and other payment instruments, as well as screening wire payments involving specific jurisdictions

On a risk based approach, a targeted third-party review by external consultants on MRBs (producers and distributors) and primary ancillary businesses to assist in decision-making at onboarding and periodically thereafter