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摘要

1. Incorporate into the documented program a risk assessment geared toward meeting accountants' and accounting firms' responsibilities in reference to exposure to possible threats related to money laundering and terrorist financing. 2. Document and maintain ongoing training of the compliance program for all applicable staff and others acting on the reporting entities' behalf. 3. Test for effectiveness and document the results and the related follow-ups of the compliance program's policies, procedures and results at least every two years. There is reason to believe that CAs act as financial intermediaries by performing triggering activities as defined by PCMLTFA. It is the responsibility of each member and not of FINTRAC to ascertain whether or not the services provided can be defined as triggering activities.