Foreign Exchange Compliance 
Commitment
Cambridge
Mercantile is committed to assisting governments
combat the threat from money laundering
and terrorist financing activities around
the world. To that end we have put in place
a Compliance Regime that addresses the requirements
both of Canada's money laundering legislation,
The Proceeds of Crime (Money Laundering)
& Terrorist Financing Act, as well as
the requirements in the United States under
the Bank Secrecy Act and the U.S.A. Patriot
Act.
“Know
Your Client”
To
a degree more than ever before, Cambridge
is required to “know your client”,
including documenting and verifying client
identification records, and tracking and
maintaining detailed records of all transactions.
Cambridge is also now required to be sensitive
to “suspicious activities”,
and “suspicious transactions”
which must be reported to FinCEN (US) and
to FinTRAC (Canada), and must be sensitive
to terrorist financing activities of individuals,
entities and countries identified by the
United Nations and other national and international
agencies.
Compliance
Regime
These
new laws require financial institutions
to implement a “Compliance Regime”
which includes appointment of a compliance
officer, preparation of policies and procedures,
periodic review of their effectiveness,
and ongoing compliance training of staff.
Cambridge currently has three fulltime employees
tasked with the responsibilities of compliance
and risk management , one of which is also
the in-house General Counsel; another is
the Risk Manager whose central responsibilities
involve due diligence. Cambridge has also
created a Compliance Committee of key department
heads which meets regularly.
Policy
and Procedures
Compliance
policies and procedures have been established,
including detailed client identification
and verification requirements. In order
to ensure compliance, Cambridge utilizes
online resources and corporate search services
to access public records when necessary.
Cambridge checks all transactions, persons
and countries involved against a comprehensive
database of undesirable persons, including
the UN terrorist lists ( see “Our
Due Diligence” below). Required reports
are filed with FinCEN and FinTRAC.
Relationships
Cambridge
cultivates ongoing relationships with the
Office of Foreign Assets Control, with FinCEN
and FinTRAC. Cambridge is also a member
of the International Financial Services
Association (IFSA).
Our
Due Diligence
We have subscribed
to and implemented the World-Check Inc.
due diligence database into our screening
and risk management procedures. World-Check
is a leader in risk management and due diligence
screening and has become the industry standard
for such due diligence procedures. See their
website at www.world-check.com
for more information about World-Check’s
services. World-Check’s extensive
database of some 800,000 names of undesirable
persons and entities, including money launderers,
drug dealers, organized criminals, financial
fraud perpetrators, terrorists, and politically
exposed persons, is culled from worldwide
sources and updated twice daily.
Should
you have any questions or concerns regarding
this matter please contact us for further
consultation.
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