If businesses needed any evidence of the importance of having adequate anti-money laundering controls in place, perhaps the possibility of a $1 billion fine that could be imposed by U.S. regulatory authorities on a financial institution for having inadequate controls will get their attention. See the link to this story at http://www.domain-b.com/finance/banks/hsbc/20120713_helping_fund.html.

In Canada, a broad range of "reporting entities" are subject to anti-money laundering (AML) regulations. These entities include financial institutions, life insurance companies, securities dealers, money services businesses, casinos, accounting and law firms, real estate brokers and developers and dealers in precious metals. In December 2011, the Canadian federal government had published some proposed amendments to the AML legislation. You can view an Osler Update on those amendments here: Canadian Government Proposes Comprehensive Amendments to Anti-Money Laundering Legislation. These proposed amendments have not been fully developed. Stay tuned.

Kashif Zaman is a partner in the firm's Financial Institutions Group.

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