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Updated May 2024
Version # Date (DD-MM-YYYY) Review and Approved
01 17-05-2024 Paul Campbell
Armoured Security Canada (ASC) is committed to maintaining an effective Anti-Money Laundering
(AML) program designed to deter, detect, and report suspicious activity, including the misuse of its
services and delivery channels related to money laundering, terrorist financing, or other activities that
may violate applicable economic sanctions.
A Compliance Officer is appointed to oversee the design, content, and implementation of ASC’s AML
program which covers money laundering, terrorist financing, and applicable economic sanctions
(collectively known as “AML program”). The program is designed to mitigate the risk of ASC services
being used for financial crime and to ensure compliance with the AML laws and regulations in
Canada.
ASC’s AML program defines the roles and responsibilities of employees in managing risk and
ensuring the relevant policies, practices, and procedures are appropriately documented and
accessible. Additionally, the AML program defines ASC’s respective risk appetite and establishes the
minimum requirements for managing the associated risks, including:
• Inherent Risk Assessments, and ongoing assessment of risk associated with client
relationships, services, and other financial crime risks;
• Client due diligence and enhanced due diligence;
• Monitoring of transactions to detect and report suspicious activity;
• Reporting transactional activity as prescribed by the applicable laws and regulations;
• Delivery of ongoing training to employees, contractors, and relevant stakeholders;
• Compliance Officer, and Management oversight of the program;
• Independent effectiveness review of the program;
• Recordkeeping and retention in accordance with applicable laws and regulations.
The effectiveness of ASC’s AML program is regularly evaluated to ensure it remains current and is
aligned with business activities, regulatory developments, industry standards, and best practices. By
doing so, ASC adheres to all applicable laws and regulatory requirements in the jurisdictions in which
it operates, including the guidance provided by the Financial Transactions and Reports Analysis
Centre of Canada (FINTRAC).