Chief Anti-Money Laundering Officer (CAMLO) - Canada

Responsibilities

• Implement and develop Alpaca's written AML, ATF and Sanctions policies and procedures.
• Assess and document money laundering and terrorist financing risks, as well as measures to mitigate high-risk situations.
• Ensure that policies are reviewed and updated, as needed or at least annually and when there are significant changes in business operations, product offerings, or client demographics.
• Report in a timely manner significant findings for violations or what may be deemed potential violations of the firm’s policy to Alpaca Canada’s, Chief Compliance Officer, and Board of Directors.
• Implement a process to ensure that all required checks for onboarding new client accounts include a customer identification, and verification process as prescribed by regulations.
• Create a risk based transaction monitoring system to ensure ongoing compliance with identifying any potential red flags, and AML concerns.
• Design a procedure that details what is considered a high-risk person or account and how the firm will monitor such accounts and activity.
• File all Suspicious Transaction Reports (STRs) with FINTRAC as soon as practicable and retain a copy for audit purposes.
• Ensure all STRs are submitted within 30 days or as needed of establishing reasonable grounds for potential suspicion activities.
• Ensure that all relevant records, such as client identification documents, account opening records, and reports, are retained for a period of at least seven years, in accordance with Alpaca Canada’s policy.
• Ensure that all employees receive training on AML procedures, including identifying suspicious transactions, record-keeping, and reporting requirements, as well as the potential penalties for non-compliance.
• Deliver training to new employees before they begin dealing with new clients.
• Maintain a training log with details of each session, attendees, and content.
• Report to the Head of Global AML & Sanctions Program, CCO and UDP on compliance matters as necessary to ensure the business is conducted in compliance with AML CIRO regulations.
• Submit an annual report to the firm’s board of directors for assessing compliance with AML CIRO Rules and applicable securities laws.
• Establish an annual independent audit for Alpaca Canada’s AML program using CIRO recognized third-party auditors.