Purpose directive_7 1 static note, 0 archetype notes Expand answer Schedule 1 item and Registered name placeholder to populate this subsection
Legal basis fic_act:s_42_1 fic_act:s_42_2 guidance_note_7 1 static note, 0 archetype notes Expand The legal basis for this RMCP includes the FIC Act provisions on customer due diligence, records, reporting, targeted financial sanctions, training and RMCP governance [1].
Drafting note: Confirm that legal basis reflects the institution's current answers, assigned owners, evidence records and cited control requirements before approval. Scope of application fic_act:s_42_1 1 static note, 0 archetype notes Expand answer Schedule 1 item and Province presence to populate this subsection
Definitions guidance_note_7 1 static note, 0 archetype notes Expand Terms used in this RMCP carry the meanings applied in the FIC Act, regulations, directives and guidance that are cited in each section [1].
Drafting note: Confirm that definitions reflects the institution's current answers, assigned owners, evidence records and cited control requirements before approval. Document control fic_act:s_42_2B 1 static note, 0 archetype notes Expand answer Registered name placeholder and Board approval date placeholder to populate this subsection
MLRO designation fic_act:s_42_1 1 static note, 0 archetype notes Expand answer MLRO name placeholder and MLRO and SCO designations to populate this subsection
SCO designation fic_act:s_26A directive_6 1 static note, 0 archetype notes Expand answer SCO name placeholder and MLRO and SCO designations to populate this subsection
Board accountability fic_act:s_42_2B 1 static note, 0 archetype notes Expand answer Supervisory body and Board or governing body composition to populate this subsection
Escalation paths fic_act:s_43 1 static note, 0 archetype notes Expand answer MLRO reporting line to populate this subsection
Conflicts of interest guidance_note_7 1 static note, 0 archetype notes Expand The institution records conflict checks where client acceptance, reporting decisions or sanctions escalation may be influenced by a commercial or personal interest.
Drafting note: Confirm that conflicts of interest reflects the institution's current answers, assigned owners, evidence records and cited control requirements before approval. Resourcing fic_act:s_42_2 1 static note, 0 archetype notes Expand answer Size band and Independent compliance function to populate this subsection
Risk factors considered guidance_note_7 pcc_53 1 static note, 0 archetype notes Expand answer Products offered, Customer types, Geographic exposure and Onboarding channels to populate this subsection
Scoring scale guidance_note_7 1 static note, 0 archetype notes Expand answer Customer risk concentration to populate this subsection
Customer risk fic_act:s_21B guidance_note_7 1 static note, 0 archetype notes Expand answer Customer types to populate this subsection
Product risk guidance_note_7 1 static note, 0 archetype notes Expand answer Products offered and Retainer model to populate this subsection
Channel risk guidance_note_7 1 static note, 0 archetype notes Expand answer Onboarding channels and Products delivered via intermediaries to populate this subsection
Geographic risk guidance_note_7 pcc_53 1 static note, 0 archetype notes Expand answer Province presence and Geographic exposure to populate this subsection
Risk appetite guidance_note_7 1 static note, 0 archetype notes Expand answer Risk appetite statement placeholder to populate this subsection
Review frequency fic_act:s_42_2 1 static note, 0 archetype notes Expand answer Board approval cadence for the RMCP to populate this subsection
Approval rules fic_act:s_21H 1 static note, 0 archetype notes Expand answer Risk appetite statement placeholder to populate this subsection
Identification standards for natural persons fic_act:s_21 directive_7 1 static note, 0 archetype notes Expand answer Identity verification methods to populate this subsection
Identification standards for legal persons fic_act:s_21B 1 static note, 0 archetype notes Expand answer Customer types and Identity verification methods to populate this subsection
Identification standards for trusts fic_act:s_21B pcc_44 1 static note, 0 archetype notes Expand answer Customer types to populate this subsection
Identification standards for partnerships fic_act:s_21B 1 static note, 0 archetype notes Expand answer Customer types to populate this subsection
Beneficial ownership identification fic_act:s_21B guidance_note_7 1 static note, 0 archetype notes Expand answer Beneficial ownership complexity typical to populate this subsection
Foreign clients fic_act:s_21A guidance_note_3A 1 static note, 0 archetype notes Expand answer Products with cross-border exposure and Geographic exposure to populate this subsection
Simplified due diligence triggers fic_act:s_21A guidance_note_7 1 static note, 0 archetype notes Expand Simplified due diligence may be applied only where the institution records why lower risk is justified and why the minimum information remains sufficient.
Drafting note: Confirm that simplified due diligence triggers reflects the institution's current answers, assigned owners, evidence records and cited control requirements before approval. Ongoing due diligence fic_act:s_21C guidance_note_7 1 static note, 0 archetype notes Expand answer Onboarding channels and Products delivered via intermediaries to populate this subsection
Identification of foreign PEPs fic_act:s_21F pcc_44 1 static note, 0 archetype notes Expand answer PEP customer exposure and PEP exposure detail placeholder to populate this subsection
Identification of domestic PEPs fic_act:s_21H pcc_44 1 static note, 0 archetype notes Expand answer PEP customer exposure and PEP exposure detail placeholder to populate this subsection
Identification of prominent influential persons fic_act:s_21H pcc_44 1 static note, 0 archetype notes Expand answer PEP customer exposure and PEP exposure detail placeholder to populate this subsection
Source of funds verification fic_act:s_21H 1 static note, 0 archetype notes Expand answer High-value low-volume products to populate this subsection
Source of wealth verification fic_act:s_21H 1 static note, 0 archetype notes Expand answer Beneficial ownership complexity typical to populate this subsection
Senior management approval fic_act:s_21F fic_act:s_21H 1 static note, 0 archetype notes Expand answer MLRO reporting line to populate this subsection
Enhanced ongoing monitoring guidance_note_7 1 static note, 0 archetype notes Expand answer PEP customer exposure and High-value low-volume products to populate this subsection
TFS list sources fic_act:s_26A directive_6 pcc_51 1 static note, 0 archetype notes Expand answer Geographic exposure to populate this subsection
Screening at onboarding fic_act:s_26A directive_6 1 static note, 0 archetype notes Expand answer Sanctions screening tool to populate this subsection
Screening at transaction directive_6 directive_9 1 static note, 0 archetype notes Expand answer Screening cadence, Directive 9 applicability and Directive 9 applicability rationale to populate this subsection
Periodic rescreening directive_6 1 static note, 0 archetype notes Expand answer Screening cadence to populate this subsection
True match handling fic_act:s_28A pcc_51 1 static note, 0 archetype notes Expand answer Sanctions screening tool to populate this subsection
Escalation deadlines directive_6 1 static note, 0 archetype notes Expand answer SCO name placeholder to populate this subsection
False positive handling directive_6 pcc_51 1 static note, 0 archetype notes Expand answer Sanctions screening tool to populate this subsection
Identification records fic_act:s_22 1 static note, 0 archetype notes Expand answer Identity verification methods to populate this subsection
Transaction records fic_act:s_22 1 static note, 0 archetype notes Expand answer Products involving trust accounts to populate this subsection
RMCP records fic_act:s_42_2B 1 static note, 0 archetype notes Expand answer Existing RMCP state to populate this subsection
Training records fic_act:s_43 1 static note, 0 archetype notes Expand answer Training programme and Training frequency to populate this subsection
Reporting records fic_act:s_29 1 static note, 0 archetype notes Expand answer Internal reporting form to populate this subsection
Retention periods fic_act:s_23 fic_act:s_24 1 static note, 0 archetype notes Expand answer Record retention period to populate this subsection
Storage and access controls fic_act:s_22 1 static note, 0 archetype notes Expand answer Technology stack for record keeping to populate this subsection
Destruction fic_act:s_23 1 static note, 0 archetype notes Expand answer Record retention period to populate this subsection
CTR reporting fic_act:s_28 mltfc_reg:r_22B 1 static note, 0 archetype notes Expand answer High-value cash acceptance and CTR threshold awareness to populate this subsection
STR reporting fic_act:s_29 guidance_note_4B 1 static note, 0 archetype notes Expand answer Internal reporting form to populate this subsection
TPR reporting fic_act:s_28A directive_6 1 static note, 0 archetype notes Expand answer Sanctions screening tool to populate this subsection
IFTR reporting directive_9 1 static note, 0 archetype notes Expand answer Products with cross-border exposure, Directive 9 applicability, Directive 9 applicability rationale and Travel rule readiness to populate this subsection
Internal escalation procedure fic_act:s_43 1 static note, 0 archetype notes Expand answer Internal reporting form and MLRO reporting line to populate this subsection
External submission procedure fic_act:s_29 directive_5 1 static note, 0 archetype notes Expand answer MLRO name placeholder and SCO name placeholder to populate this subsection
Accountable persons fic_act:s_43 1 static note, 0 archetype notes Expand answer MLRO name placeholder and SCO name placeholder to populate this subsection
Induction training fic_act:s_43 1 static note, 0 archetype notes Expand answer Training programme to populate this subsection
Refresher training fic_act:s_43 1 static note, 0 archetype notes Expand answer Training programme and Training frequency to populate this subsection
Role-specific training guidance_note_7 1 static note, 0 archetype notes Expand answer Size band and Products offered to populate this subsection
Training records fic_act:s_43 1 static note, 0 archetype notes Expand answer Training programme to populate this subsection
Training effectiveness guidance_note_7 1 static note, 0 archetype notes Expand answer Training programme to populate this subsection
Transaction monitoring fic_act:s_21A guidance_note_7 1 static note, 0 archetype notes Expand answer Products involving trust accounts and Retainer model to populate this subsection
Periodic RMCP review fic_act:s_42_2 1 static note, 0 archetype notes Expand answer Board approval cadence for the RMCP to populate this subsection
Risk assessment review guidance_note_7 1 static note, 0 archetype notes Expand answer Geographic exposure and Products offered to populate this subsection
Control testing fic_act:s_45 1 static note, 0 archetype notes Expand answer Historical findings to populate this subsection
Internal audit fic_act:s_42_2 1 static note, 0 archetype notes Expand answer Independent compliance function to populate this subsection
External audit fic_act:s_45A 1 static note, 0 archetype notes Expand answer Historical findings to populate this subsection
Implementation timeline fic_act:s_42_1 1 static note, 0 archetype notes Expand answer Open issues placeholder and Historical findings to populate this subsection
Board approval fic_act:s_42_2B 1 static note, 0 archetype notes Expand answer Board approval cadence for the RMCP and Board approval date placeholder to populate this subsection
Communication to staff fic_act:s_43 1 static note, 0 archetype notes Expand answer Size band to populate this subsection
Transitional arrangements guidance_note_7 1 static note, 0 archetype notes Expand answer Existing RMCP state to populate this subsection
Version control fic_act:s_42_2B 1 static note, 0 archetype notes Expand answer Existing RMCP state to populate this subsection