the FINTRAC Audit noted the following:

1. The review of your compliance policies and procedures was not performed every two years and when reviews did take place, corrective measures and follow-up actions were not taken.
2. Compliance Policies and Procedures (for AML) were inadequate and not up to date.
3. There was little or no AML/ATF training for employees.
4. The assessment and documentation of risks related to money laundering and terrorist financing were inadequate.

You are required to submit a report, outlining an action plan and recommendations to address the noted FINTRAC Audit deficiencies. The report will also need to highlight and summarize the key components and structure of your firm`s AML Compliance Regime.