RBC Financial Group Global Approach to
Anti-Money Laundering
RBC Financial Group ("RBC") has enterprise-wide
policies covering Anti-Money Laundering, Client Due Diligence,
Terrorist Financing and Economic Sanctions that set forth
minimum cross-enterprise standards. These policies are designed
to guide RBC's various businesses in setting up their own
policies, guidelines and processes to ensure compliance with
Canada's anti-money laundering laws and regulations and with
various other anti-money laundering laws and regulations to
which RBC operations are subject in other jurisdictions in
which they operate. Canada's laws are designed to be consistent
with FATF recommendations and other international standards.
Units operating in jurisdictions whose laws set higher standards
than those contained in the policy must comply with the higher
local standards.
Canadian regulatory obligations cover the reporting of suspicious
transactions, large cash transaction reporting, electronic
funds transfer reporting, reporting of cross border movements
of cash and monetary instruments, client identification and
verification as well as terrorist financing reporting requirements.
RBC defines money laundering as any act or attempt to disguise
the source of money or assets derived from criminal activity.
Money laundering is a criminal offence in Canada and many
other jurisdictions in which RBC does business. RBC is committed
to preventing the use of its financial services for money-laundering
purposes, by establishing policies and processes to ensure
that:
- only those whose activities can reasonably be established
to be legitimate are accepted as clients,
- staff are trained to recognize and react appropriately
to unusual or potential money-laundering activity and understand
their legal obligations to report activity and transactions,
and
- appropriate records of client information and transactions
are retained.
Each platform and/or business is required to assess its operations
to identify potential money laundering risks and establish
policies, procedures, guidelines and risk mitigation strategies,
specific to its business and potential money laundering risk
and in compliance with relevant local laws, to implement these
objectives.
RBC's Policy requires that its businesses identify reportable
activities and transactions in each jurisdiction in which
they operate and establish processes to ensure reporting as
required. In addition, RBC businesses are required to establish
processes to identify and investigate unusual activities and
transactions and ensure that all activities and transactions
reasonably suspected to be related to money laundering are
reported to the RBC Designated Money Laundering Officer.
RBC businesses are required to take reasonable and appropriate
measures to establish the identities of their clients and
others for whom they may provide financial services, and to
open accounts and conduct transactions only after identity
is verified to RBC's satisfaction.
RBC Policy requires businesses to document the measures taken
to identify clients and retain records of the due diligence
measures taken for at least 5 years after the account in question
is closed.
Anti-terrorism and Know Your Client policies
In addition, RBC has developed enterprise-wide policies and
procedures regarding compliance with economic sanctions and
anti-terrorism legislation, as well as an enterprise-wide
client due diligence policy. These policies also constitute
minimum standards for the enterprise in these areas.
Audit
RBC Internal Audit (IAS) reviews business units' Anti-Money
Laundering, Anti-Terrorism, Economic Sanctions and Client
Due Diligence Programs for compliance with the relevant policies,
procedures and regulations in all relevant audits completed
during each audit cycle. In addition, IAS from time to time
conducts enterprise-wide audits specific to these areas.
Technological Tools
RBC has developed and implemented various solutions to assist
in complying with the reporting obligations including the
development and rollout of a suspicious activity reporting
system and large cash reporting system for all staff. In addition,
RBC has developed a client name scanning system that searches
all client databases nightly against various control lists
to ensure that RBC is not knowingly doing business with a
listed individual or entity. As part of its effort to enhance
its ability to identify suspicious transactions and activity,
RBC has implemented a global money laundering transaction
monitoring system that reviews transactions on a daily basis.
Oversight
RBC has established a senior-level management position and
team dedicated to the task of overseeing its global policies,
practices and procedures with regard to anti-money laundering
and anti-terrorist financing. In addition, the development
of AML programs within the various businesses is evidence
of the commitment of senior management to the implementation
of appropriate controls and compliance procedures across RBC
businesses.
For further information, please contact:
Karim Rajwani
Global Head, Anti-Money Laundering
Group Risk Management
Royal Bank of Canada
Royal Trust Tower
9th floor, 77 King Street West
Toronto, Ontario
M5W 1P9 Canada
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