What this covers
Screening obligations in this market
Screen, assess, document, and monitor against one transparent corpus — reframed to the authorities and statutes you answer to.
◧ ObligationScreen — continuing-basis sanctions checks
SEMA, the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) (JVCFOA), and the United Nations Act require reporting entities to determine — on a continuing basis, not as a one-time check — whether they deal with property owned or controlled by a listed person. Screen checks names against the Consolidated Canadian Autonomous Sanctions List and the UN Consolidated list.
◧ ObligationAssess — PEP identification and enhanced due diligence
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) requires enhanced due diligence for domestic and foreign politically exposed persons and heads of international organizations. Assess surfaces PEP status and match context so your team can make and support that determination.
◧ ObligationDocument — recordkeeping and a compliance program
FINTRAC requires reporting entities to keep records and maintain a documented compliance program, and to file suspicious transaction reports as soon as practicable once grounds to suspect are established — no dollar threshold. Document keeps a case workspace and audit trail behind every screening decision.
◧ ObligationMonitor — ongoing review
The PCMLTFA's continuing-basis and periodic-review obligations don't stop at onboarding. Monitor is the stage we're building out to support re-screening against updated lists over time — today it's directional, not a shipped continuous feed.