International anti‐money laundering and anti‐terrorist financing: the work of the Office of the Superintendent of Financial Institutions in Canada

DOIhttps://doi.org/10.1108/13685200410810038
Pages320-332
Date01 October 2004
Published date01 October 2004
AuthorNicolas W. R. Burbidge
Subject MatterAccounting & finance
Journal of Money Laundering Control Ð Vol. 7 No. 4
International Anti-Money Laundering and Anti-
Terrorist Financing: The Work of the Oce of the
Superintendent of Financial Institutions in Canada
Nicolas W. R. Burbidge
INTRODUCTION
This paper focuses on the background and application
of international anti-money laundering and anti-
terrorist ®nancing measures as they relate to ®nancial
institutions and their supervisors; and summarises the
approach and activities of the Oce of the Superinten-
dent of Financial Institutions (OSFI) in these areas.
It also notes two current areas of economic crime
impacting ®nancial institutions.
OSFI'S MANDATE AND MISSION
The OSFI is the primary regulator of federally char-
tered ®nancial institutions and federally administered
pension plans. The OSFI's mission is to safeguard pol-
icyholders, depositors and pension plan members
from undue loss. The OSFI supervises and regulates
all banks, all federally incorporated or registered
trust and loan companies, insurance companies, coop-
erative credit associations, fraternal bene®t societies
and pension plans.
The OSFI takes a risk-focused approach to supervi-
sion in order to accomplish its mandate. This means
close attention is paid to the key risks that ®nancial
institutions are taking and the quality of the manage-
ment programmes and governance systems they have
put in place to manage those risks. Financial insti-
tutions are required to ®le certain information with
the OSFI on an ongoing basis. Regular on-site exam-
inations of a ®nancial institution's operations are also
undertaken.
THE GROWING MONEY LAUNDERING
PROBLEM
There is no question that over the past several years,
governments, regulators, bankers and other ®nancial
executives have realised that the systemic abuse of
the world's ®nancial systems by money launderers is
a threat to the con®dence the public has in those
systems.
The International Monetary Fund (IMF) has
estimated that the amount of money laundering
occurring on a yearly basis could range between 2
and 5 per cent of the world's gross domestic product
Ð or somewhere between US$600bn and
US$1.5trn. Estimates come from a variety of sources
based upon both macroeconomic theories and on
microeconomic approaches. The US Department of
the Treasury has suggested that US$600bn represents
a conservative estimate of the amount of money laun-
dered each year. Some estimates
1
suggest that the
amount of money laundered each year is approxi-
mately US$2.8trn, an amount more than four times
greater than the ®gure generally accepted. Due to
the clandestine nature of laundering activity,
governments and concerned organisations cannot
accurately quantify the amount of money laundered
each year.
Here are just a few examples of how illicit ®nancial
¯ows can aect the economy and institutions of the
host country.
Financial institutions that accept illegal funds
cannot rely on those funds as a stable deposit
base. Large amounts of laundered funds are
likely to be suddenly wired out to other ®nancial
markets as part of the laundering process, threa-
tening the institution's liquidity and solvency. A
®nancial institution's reputation and integrity
can be irrevocably harmed if involved in money
laundering or ®nancing terrorism.
Local merchants and businesses may ®nd that they
cannot compete with front companies organised
to launder and conceal illicit funds. Many such
front companies oer their services and goods at
below-market rates and even at a loss. Because
their primary objective is the laundering of
money, they do not need to compete in the
marketplace and make a pro®t for their owners.
Money laundering may also distort some econ-
omic sectors and create instability in their mar-
kets. Money launderers may channel funds to
sectors or areas where funds are unlikely to be
discovered whether or not investment is needed
or real returns are oered. The often sudden
Page 320
Journalof Money Laundering Control
Vol.7, No. 4, 2004, pp. 320± 332
#HenryStewart Publications
ISSN1368-5201

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