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BLOCKCHAINforJudges.org; BLOCKCHAINforLawyers.com

GLOBAL FINCOM™

MQCC® Global Finance Compliance

BASED IN CALGARY, ALBERTA, CANADA • SERVING 118+ COUNTRIES

Services for the World's Governments, Banks, Trusts, Lenders,

Investors, Brokers & their Regulators

...since before May 9, 2008.

www.GlobalFinCom.com

🌐 United Nations Principles Based

🌍 Financial Action Task Force (FATF) Aligned; Canada is a Founding Member in 1989

🎀 ISO 9001:2015 Registered Since May 9, 2008

🏢Standards Trusted by 100% of Risk-Based Regulators

The MQCC® BUNGAY Global Finance Sector Regulatory Requirements Ledger™

"The Minimum 20™": An Adaptive Comprehensive Conformity Framework

Integrating National and International Standards of up to 118+ Countries including Canada, USA, UK (see country.mqcc.org)

Blue for standard conformity (compliance) items and Yellow/Gold for high-level governance/licensing items. Not every item applies to all industry groups.

Anti-Money Laundering (AML)

Program Creation
Risk Assessment
Enhanced Due Diligence

Not a complete list

Countering Terrorist Financing (CFT)

Sanctions Screening
Terrorist Property Reporting
UN Sanctions Compliance

Not a complete list

Proliferation Financing (CPF)

Dual-use Goods Checks
Supply Chain Analysis
Nuclear/Bio Weapon Checks

Not a complete list

Know-Your-Client (KYC)

Identity Verification
Dual ID Methods
Source of Funds

Not a complete list

Fit & Proper Requirements

Integrity Assessment
Criminal Checks
Financial Soundness

Not a complete list

Consumer Protection & Fair Dealing

Cost of Credit Disclosure
Interest Rate Transparency
Conflict of Interest Mgmt

Not a complete list

Privacy & Data Protection

PIPEDA/GDPR Compliance
Data Breach Reporting
Secure Storage

Not a complete list

Corporate Governance

Board Standards
Internal Controls
Audit Trails

Not a complete list

Prudential (Capital & Liquidity)

Minimum Capital
Liquidity Mgmt
Risk-Weighted Assets

Not a complete list

Record Keeping

Transaction Docs
AML Reporting Records
7-10 Year Retention

Not a complete list

Cross-Border Finance

Correspondent Banking
Sanctions/Embargoes
Offshore Reporting

Not a complete list

Licensing & Registration

MSB Registration
Mortgage Licensing
Securities Registration

Not a complete list

Digital Asset & Token-Based Finance

Utility Token Class.
Stablecoin Compliance
Travel Rule (Crypto)

Not a complete list

Beneficial Ownership (BO)

Identify UBOs
Registry Submission
Trust Beneficiary Disc.

Not a complete list

Real Estate Specific Requirements

Property ID Verification
Land Registry Accuracy
Construction Draw Audit

Not a complete list

Non-Real Estate Financing

Chattel Registration
Inventory Audit
Equipment Lien Perfection

Not a complete list

Reporting Requirements

STR/SAR Filing
Threshold Reporting
Regulatory Notices

Not a complete list

Independent Review

AML Program Audit
Controls Testing
Regulator Readiness

Not a complete list

Training & Competency

Annual AML Training
Privacy Training
Global Updates

Not a complete list

MQCC® MQCCBIT™ Quantum-Unified Trust-Layer & Identity™

TFID™ Identity Reg.
Conformity Science™
Data Packet Integrity

Not a complete list

Not a complete list of ledger categories.

Services for Companies, Organizations or Individuals (COIN™)

Get MQCC® Bungay to help you fulfill your real-time, daily, weekly, monthly, quarterly, annual, bi-annual or ad hoc government or licensing body, regulatory requirements and obligations in any MQCC®-Approved Country.

MQCC® Services Available For

🏢 Institutions

✓ Banks

✓ Non-Banks (Credit Unions)

✓ Mortgage Investment Corps

✓ Corporate Lenders

🅯 Private Clients

✓ Individual Private Lenders

✓ Mortgage Investors

✓ Family Offices

💼Professionals

✓ Legal Professionals

✓ Mortgage Brokers

✓ Mortgage Administrators

✓ Investment Advisors

Your Regulatory Obligations are a LIVING SYSTEM

______

Conformity (not mere compliance) is not a one-time event.
It has a heartbeat.

CEOs, Boards, Individual or Family Office Investors of Mortgage Instruments and their Federally Required (see FATF) Conformity Officers, must --as a unified team -- maintain their organization’s:

Generic Statutory and Regulatory Conformity Processes

— AT BOTH REGULATOR AND REGULATEE LEVELS.

An organization must regulate its statutory, regulatory or other rules-bound process cycles, and leadership must act as the regulator ensuring the rhythm remains intact.

Your Solution? The Bungay Circaregulatory System™ of continuous conformity to statutory, regulatory and process requirements; built on the principles, concepts and core methods of non-novel (exact) conformity science.

CONFORMITY SCIENCE™

The Bungay Circaregulatory System™

Regulatory adherence is not a static burden. It is a dynamic, "living system" essential for sustainable operation.

/\/\__ The Bungay Circaregulatory System Rhythm™

Just as the human body relies on a 24-hour internal clock for health, an organization requires a continuous "Heartbeat of Conformity".

"Disruption to this rhythm leads to organizational 'illness'—market failure, penalties, and reputational damage."

🧬 Anoop Bungay: Mapping Biology to Business

🕓Circadian System = Annual Strategy

Regulates operational phases (project initiation/closure) just as the body regulates sleep/wake cycles.

🧠 Central Clock (Brain) = Governance Suite

The Executive Leadership acts as the Suprachiasmatic Nucleus (SCN), synchronizing the organization with market demands and regulatory deadlines.

❤️ــﮩ٨ـ💔Health vs. Disease = Conformity vs. Penalty

Disruption leads to health issues in humans, and Administrative Monetary Penalties (AMPs) in business.

Bungay Circaregulatory System™

Mapping Biology to Business: The Bungay Abstraction of System Analogy

The Bungay system draws a direct parallel between the human body's 24-hour internal clock and an organization's operational cycles:

Human Biological Function

Circadian System (internal clock)

Regulates Sleep/Wake Cycles

Central Clock (SCN in brain)

Synchronized by Sunlight

Healthy Sleep & Energy Levels

(!) Disruption Leads to Health Issues

Organization & Conformity Function

Bungay Circaregulatory System™ (internal quantum-unified governance, management and operations mechanism)

Regulates Operational Phases (project initiation/closure)

Central Governance Clock (Executive Leadership Suite)

Synchronized by Market Demands, Regulatory Deadlines

Resource Allocation & Sustainable Growth

(!) Disruption Leads to Market Failure or Penalties

The Temporal Dimensions of the Bungay Circaregulatory System™ Rhythm

Real-Time

Immediate threat detection and continuous transaction monitoring (e.g., P2P finance).

Daily / Weekly

Routine operational checks, system balancing, and management huddles.

Monthly / Quarterly

Internal conformity audits, financial statements, and performance reviews.

Annual / Bi-Annual

Comprehensive external audits, mandatory regulatory submissions, and strategic planning.

The Bungay Circaregulatory System™ is A Core Component of

Bungay International Technology Conformity of Organization and Individual Network

BITCOIN®

The Power of the OFFICIAL AUTHENTIC ORIGINAL (OAO)® BITCOIN® System

The one and only utility function ever created to achieve this at true peer-to-peer scale.

OFFICIAL AUTHENTIC ORIGINAL (OAO)® BITCOIN® is a utility system that reduces the risk of financial loss, volatility, and operational disorder by creating, encapsulating, maintaining, and transmitting economic value at a peer-to-peer scale.

MQCC® BUNGAY: Global Regulatory Architecture

The Superordinate Level

Global Standard-Setters

FATF
OECD
BIS (Basel)
IMF & World Bank

National Regulators

FINTRAC / OSFI (CAN)
FINCEN / SEC (USA)
FCA / PRA (UK)
EBA / ESMA (EU)

FRFI (Federally Regulated Financial Institutions) vs Non-FRFI

Banks & Trusts (FRFI)
Credit Unions
Trust Companies, Pensions
MICs / Mortgage Funds
Private Finance (see IP2PFA™ at www.ip2pfa.org)

The Bungay 5 Orders™

Bungay MQCC® Unified Global Financial Taxonomy

View Taxonomy →

The Bungay 5 Orders of Global Finance™

The world’s one and only complete classification system for all financial assets, instruments, products, and methods.

BUNGAY Order 1: Real Estate Asset-Secured Financing

Genus → Species → Category → Class™

Residential
Commercial
Industrial
Construction
Agricultural
Luxury
Offshore
Special Purpose
Not a complete list

BUNGAY Order 2: Non-Real Estate Asset-Secured Financing

Equipment/Machinery
A/R & PO Finance
Inventory
Agri-Chattel
Fine Art/Metals
Debtor-in-Possession/Bridge (interim)
Not a complete list

BUNGAY Order 3: Organization-Level (Economic Ownership)

Mergers & Acquisitions
Joint Ventures
Management Buyouts
Not a complete list

BUNGAY Order 4: Binary Digit Utility Tokens (New Order™ 1)

Governance Tokens
Identity/Access
Quality Management System Tokens
Not a complete list

BUNGAY Order 5: Binary Digit Value Tokens (New Order™ 2)

Currency Tokens
Tokenized Debt/Asset
Tokenized Real Estate
Not a complete list

Mandatory Legal Entry Path

All clients must be onboarded through a lawyer. This ensures liability protection, AML validation, and Conformity Science™ integration.

BlockchainForLawyers™ Gateway

Lawyer Intake Gateway™

MQCC® does not onboard private lenders directly. Only a licensed lawyer may initiate a file. This protects the client, the lawyer, and the regulatory ecosystem.
Any interested lawyer must send an email to info@mqcc.org with the below content. Just copy-paste into an email and fill in the answers.

Lawyer Authentication

Disclose your Full Name
Disclose your Law Society ID or Law Society Regulatory Body Name
Disclose your Law Firm Name

Client & Transaction

Disclose your Client Legal Entity
Disclose your Client Jurisdiction
Disclose your Bungay 5 Orders of Global Finance™ Taxonomy Classification
- - - - Order 1: Real-Estate Secured
      - Order 2: Non-Real-Estate Secured
      - Order 3: (Equity/Control)
      - Order 4: (Utility Token)
      - Order 5: (Value Token)
      - Or combination of Orders

AML/CTF Certification

I verify that I have identified the beneficial owners of this client.
I am satisfied as to the lawful purpose of the funds involved.
I authorize MQCC® to open a Conformity File based on this attestation.

MQCC® Global

The world’s first superordinate global financial compliance gateway. Powered by Conformity Science™.

ISO 9001:2015 Registered

Domains

globalfinancecompliance.com
privatelendercompliance.com
fintraccompliance.com
BlockchainForLawyers™
Not a complete list

Regulators

FATF / OECD / BIS
FINTRAC (Canada)
FINCEN (USA)
FCA (UK)
Not a complete list

Contact

Lawyer Referral Only

No direct public onboarding.

LAWYER LOGIN

Unauthorized use of the Bungay 5-Order Global Financial Taxonomy™ is strictly prohibited.

Welcome to MQCC® MORTGAGE COMPLIANCE ORGANIZATION (www.MortgageCompliance.org); A Service of MQCC®: Your World Leader in Global Finance Compliance since before May 9, 2008.

Global Notice

Attention: Corporate, Organization or Individual; Mortgage Lenders, Mortgage Brokers and Mortgage Administrators

in Canada and many of these countries (country.mqcc.org), as of October 11, 2024:

You Are Now

A Federal Government Reporting Entity.

Turn Your Regulatory Burden into Business Conformity.

🌐

FATF/OECD

Aligned Standards

🛡️

FINTRAC

PCMLTFA Experts

The new FINTRAC requirements for Mortgage Administrators, Brokers, and Lenders are complex. MQCC® Compliance Infrastructure shields your business using standards trusted by 100% of risk-based financial regulatory bodies.

🎀

Since 2008

Global Finance Compliance Leadership

⌨ MQCC® Compliance Infrastructure-As-A-Service (COMPLIAAS™)

MQCC® builds the regulatory rails. You drive the train. MQCC® provide the systems, technology, and standards; you maintain control and liability.

*Full Managed Services available at premium rates.

The Regulatory Threat Landscape to Finance Sector Trading in Real Estate

As of October 11, 2024, if you fall into these categories, you are a "Reporting Entity". You must own your risk. Ignorance of the law is not a defense against Administrative Monetary Penalties (AMPs).

❉ Mortgage Administrators

Servicing agreements on behalf of lenders? You are now fully liable for AML monitoring.

🚹Mortgage Brokers

Intermediaries between lenders and borrowers must now verify identity and report suspicious transactions.

🏦 Mortgage Lenders

Providing loans secured by real property? You have the same obligations as a bank; regardless of individual or corporation; RRSP or Non-RRSP funds!

Do Not Believe MQCC®?

See The Inevitable Penalties (AMPs)

These penalties are real. They are public. They are happening right now (2025).
The Mortgage and Real Estate sector is under direct fire.

Real Estate Brokerage Avg. Penalty

$73,636

Based on recent 2025 filings below

Total Listed Below

19 Entities

Just a snapshot of recent enforcement

Sector Risk

📈 Critical

Mortgage Admin/Broker/Lender Focus

"The mortgage sector AMPs are inevitable and will be published once publicly disclosed. Don't be next on this list."

Why? The Dangerous Misconception

The Trinity's Blind Spot

The trinity of Administrators, Brokers, and Lenders often ignore the most critical sentence in the regulations:
"A strong compliance program will form the basis of meeting your regulatory requirements."

ⓧ The Amateur View (Failure)

"I just need to check their ID."

1. Get Client ID (KYC)

...ignoring the other 4 pillars.

Result: Administrative Monetary Penalties (AMPs)

🗹 The Professional Reality

Applies to All 3: Mortgage Administrators, Brokers, Lenders

1 Compliance Program (The Foundation)

2 Know Your Client (KYC)

3 Report Transactions (STRs/LCTRs)

4 Keep Records

5 Apply Ministerial Directives

Discover MQCC® COMPLIAAS™

MQCC® Provides The Conformity System. You Operate The Compliance.

MQCC® delivers the infrastructure to meet "Prescribed" requirements. You execute the daily work and assume the risk.

(Managed Services available as an add-on for higher fees)

⚙ Compliance (Conformity) Program Framework

Infrastructure Capability

The Law: You must implement a compliance program immediately.

Infrastructure Provided: MQCC® delivers the pre-architected Policies & Procedures manuals and Risk Assessment models. You customize and enforce them.

👤 KYC & Entity Verification Logic

Infrastructure Capability

The Law: You must verify identity using prescribed methods.

Infrastructure Provided: MQCC® system provides the standard-based verification workflows and Beneficial Ownership logic trees. You perform the verification steps.

🔍 Monitoring Systems Architecture

Infrastructure Capability

The Law: Ongoing monitoring is required for business relationships.

Infrastructure Provided: MQCC® deploys the detection algorithms and monitoring dashboards. Your analysts must review the alerts and document decisions.

🗎 Reporting Workflows & Templates

Infrastructure Capability

The Law: Strict deadlines for STRs, Large Cash ($10k+), and VC reports.

Infrastructure Provided: MQCC® provide the digital reporting tunnels and calibrated templates. You are responsible for the timely submission and accuracy of data.

🌎Sanctions Database Access

Infrastructure Capability

The Law: You must determine if clients are PEPs or Sanctioned entities.

Infrastructure Provided: Real-time API access to global sanctions lists. You must act on the positive hits.

🛑 Warning: MQCC® Infrastructure enables compliance. It does not replace your duty to act.

Why Trust MQCC®?

Regulatory compliance requires systems that are not "amateur." MQCC® is built on a history of defining the standards themselves.

ISO 9001:2015 Registered

Risk-Based Quality Management Systems

Registered Since May 9, 2008

Unmatched Heritage

"There is no more experienced company in human history" regarding these systems.

Included Infrastructure:

MQCC® Red Flags Checker™

Our proprietary diagnostic infrastructure identifies specific indicators FINTRAC examiners look for.

⚠ Real Estate Transaction Red Flags

⚠ Private Lender Risk Indicators

⚠ Corporate Structuring & Beneficial Ownership Concealment

⚠ Cross-Border Financing Risks

⚠ Construction Financing Irregularities

Ministerial Directives Ready

MQCC® system automatically applies ministerial directives regarding transaction restrictions to high-risk jurisdictions.

Need Full Service?

MQCC® can perform the compliance services for you, but this is a premium, partitive service separate from the base infrastructure fee.

Inquire About Premium Service at info@mqcc.org

Strict Intake Protocol

To ensure the highest standards of privilege and professional conduct, MQCC® does not accept direct public onboarding.

We only accept clients through their LAWYER.

Please ask your legal counsel to contact us regarding the "MQCC® COMPLIAAS™".

MQCC® Standards: Trusted by 100% of Risk-Based Financial Regulatory Bodies

MQCC® PRIVATE LENDER COMPLIANCE (Conformity) CENTRE™

The world’s one and only complete classification system for all financial assets, instruments, products, and methods.

Attention: Individual or Corporate Private Mortgage Lenders; Under the October 11, 2024 Federal AML rules,

private lending is no longer free trading

⚖️ Ignorance is no longer a defense.

Do you invest or lend directly in mortgages using your personal cash, company funds, or self-directed RRSP?

❓ Ask Yourself (or your Lawyer):

➀ Do you tell mortgage brokers, friends, or family that "you are a private lender" or "in the money lending business", even occasionally?

➁ Do you or your numbered company lend funds, even occasionally, secured by mortgages on real property?

➂ Are you involved, even occasionally, in residential or commercial loans secured by real property?

➃ Do you approve or deny mortgage loan applications, even occasionally?

➄ Would a public land titles search show your name (or corp) as a registered mortgagee on at least one transaction?

------------------------------------THE VERDICT------------------------------------

If you answered "YES" to ANY of the above five questions:

YOU ARE A

PRIVATE LENDER

---------------------------------

FEDERAL REPORTING ENTITY STATUS: CONFIRMED

You MUST CONFORM to FINTRAC & PCMLTFA

Federal Law Requirements

__________________

including Regulations.

⚠ If you do not believe this; ask any government licensed law firm or lawyer, or just ask your local politician who represents you in your jurisdiction of business activity or residence.

FATF (Global) • FINTRAC (Canada) • FINCEN (USA)• FCA (UK) Aligned Architecture

The world’s one and only standards-integrated, multi-jurisdictional compliance system for Corporate Private Lenders, Individual Private Lenders, MICs, and Holdcos.

IMPORTANT

MQCC® only accepts private lending clients through their LAWYER. No direct onboarding.

Who Qualifies?

Private Lenders (Individual/Couple)
Holdco Lenders
RRSP Self-Directed Lenders
Private Credit Companies
Construction Lenders
Bungay 5 Orders of Global Finance™: Orders 1-5 Asset Classes

MQCC® Private Lender Compliance (Conformity) Service Pricing

Professional Grade • Standards-Based • Risk Shielding

Setup Fee

(disclosed via lawyers during MQCC® Intake Process)

Lender-of-Record Access & Conformity Activation

Annual Governance

(disclosed via lawyers during MQCC® Intake Process)

Per Year (AML/Conformity)

Per File Fee

(disclosed via lawyers during MQCC® Intake Process)

Of Loan Amount (File Governance)

Ongoing Monitoring

(disclosed via lawyers during MQCC® Intake Process)

Per Month / Per Mortgage

⨻ ATTENTION PRIVATE LENDERS

You Are Now

A Reporting Entity.

The "Passive Investor" exemption is gone. If you live in one of these countries (country.mqcc.org) Conform to Global federal AML (anti-money laundering) and CFT (combatting terrorism financing) oversight or face the consequences.

MQCC® BUNGAY: Built on Standards Trusted by Regulatory Bodies and Regulatees, Worldwide

Defining de jure-integrated de facto Standards Since May 9, 2008.

Are You Non-Compliant?

The Canada Example: PCMLTFA: Proceeds of Crime (Money Laundering) and Terrorist Financing Act

Equivalent under FATF to UK (FCA) and USA (FINCEN) or other country implementations

The PCMLTFA Amendments: The Hard Truths

The Canada landscape has changed. Federal AML oversight now captures entities of all sizes involved in the mortgage lending process.

No More Exemptions

Is your layered corporate structure exempt? No.

The amendments explicitly capture entities of all sizes—brokers, lenders, and administrators. This creates a level playing field with banks.

Your self-identification as a "passive investor" is irrelevant to the law. Even ONE transaction may count

Source: Canada Gazette, Part I, Vol 157, No. 7 or ask via email: guidelines-lignesdirectrices@fintrac-canafe.gc.ca

High-Risk Triggers

Do mortgage applications have unverifiable income or asset facts? mortgage applications + unverifiable facts = High Risk? Yes.

This combination requires special measures. If these elements raise reasonable grounds to suspect money laundering, you must file a Suspicious Transaction Report (STR).

Atypical transactional activity
Lack of transparency on source of funds or income or assets

Source: FINTRAC Guidelines or ask via email: guidelines-lignesdirectrices@fintrac-canafe.gc.ca

Corporate Lenders or Individual Investors

Can a construction lender claim the 'private passive investor' exemption? No.

If your numbered company is identified as the lender in a loan agreement secured by real property, you are a reporting entity.

Direct involvement is the key criterion. Occasional lending still counts.

Source: Ask via email: guidelines-lignesdirectrices@fintrac-canafe.gc.ca

Ask yourself: Are you prepared to risk it all?

MQCC® Private Lender Compliance Centre™

The world’s one and only complete compliance (conformity) system service for all financial assets.

1. Do you tell brokers, friends, or family that 'you are a private lender' or in the 'money lending business', even occasionally?

2. Do you or your numbered company lend funds, even occasionally, secured by mortgages on real property?

3. Are you involved, even occasionally, in residential or commercial loans secured by real property?

4. Do you approve or deny mortgage loan applications, even occasionally?

5. Would a public land titles search show your name (or corp) as a registered mortgagee on at least one transaction?

⚠ Answer Yes to even one of the above questions:

YOU ARE A PRIVATE LENDER

You MUST conform to FINTRAC & PCMLTFA Federal Law requirements.

Ignorance is not a defense. Ask your local politician or lawyer if you doubt this.

MQCC® Bungay Professional Grade Conformity Services

MQCC® Bungay: Services Available in 118+ Countries.

Global Finance Compliance (conformity) Since before 2008

Who MQCC® Serves

Private Lenders (Individual/Couple)
Holdco Lenders & Family Offices
RRSP Self-Directed Lenders
Private Credit Companies
Construction Lenders
Banks & Non-Banks
Mortgage Brokers or their investor customers

MQCC® Pricing Structure

*All pricing disclosed via lawyers during MQCC® Intake Process

Setup Fee Lender-of-Record Access
Annual Governance Per Year (AML/Conformity)
Per File Fee % of Loan Amount
Ongoing Monitoring Per Month / Per Mortgage

Important: Intake Protocol

To ensure the highest standards of privilege and professional conduct, MQCC® does not accept direct onboarding.

MQCC® only accepts private lending clients through their LAWYER.

Ask your lawyer to contact us regarding the "MQCC® Private Lender Compliance (Conformity) Service".

MQCC® Bungay 5 Orders of Global Finance™: Orders 1-5 Asset Classes

FATF (Global) • FINTRAC (Canada) • FINCEN (USA) • FCA (UK) Aligned Architecture

𖠩 ATTENTION MORTGAGE ADMINISTRATORS, MORTGAGE BROKERS, MORTGAGE LENDERS

The Business Relationship

Has Changed Forever.

Processing payments. Negotiating loans. Funding. Renewals.

Every action is now bound by Prescribed Regulatory Standards.

⚠ Critical Warning

It is not enough for you to implement these standards. Your private lenders must also comply. A chain is only as strong as its weakest link.

When is the Relationship Created?

Under the new FINTRAC enforced PCMLTFA regime, a "Business Relationship" is strictly defined. The moment you engage in any of the following activities, the regulatory clock starts ticking.

▶ Processing Mortgage Payments

▶ Funding Mortgage Loans

▶ Negotiating Mortgage Loans

▶ Mortgage Renewals

⚖

The MQCC® BUNGAY FINTRAC PCMLTFA 14 PRESCRIPTIONS™

Your "Prescribed Law" Environment

www.prescribedlaw.com

All activities must be executed within 14 specific "prescriptions" set by the regulations. Deviating from the prescribed manner is a compliance (conformity) failure.

Prescribed Manner

2. Prescribed Information

3. Prescribed Record

4. Prescribed Disbursement

5. Prescribed Penalty

6. Prescribed Max Penalty

7. Prescribed Period

8. Prescribed Circumstances

9. Prescribed Measures

10. Prescribed Transaction

11. Prescribed Enhanced Monitoring

12. Prescribed Special Measures

13. Prescribed Client Activities

14. Prescribed Range

Mandatory Compliance Framework

☰ 1. Program & KYC

Compliance Program:Must be implemented immediately. Forms the basis of meeting requirements.
1. 1. 1. Appoint a Compliance (conformity) officer
    2. Bi-Annual (two year) Effectiveness Review
Risk Assessment: Ongoing guidance and documentation of risk levels.
Know Your Client (KYC):Mandatory verification of identity for persons and entities using prescribed methods.

🔍 2. Monitoring & Entities

Ongoing Monitoring:Required from the moment a business relationship is entered.
Beneficial Ownership:Must take reasonable measures to confirm accuracy of entity ownership.
PEPs & HIOs:Must determine if clients are Politically Exposed Persons or Heads of Int'l Orgs.

🛑 3. Mandatory Reporting

Submit to FINTRAC via F2R System

Suspicious Transaction Reports (STR)
Listed Person/Entity Property Reports
Large Cash Transaction Reports (24hr rule)
Large Virtual Currency Reports (24hr rule)
Sanctions Evasion Reports

🏦 FINTRAC Assessments

FINTRAC is authorized to conduct compliance examinations. They will review your program implementation, reporting history, client ID records, and third-party determinations.

Consequence of Non-Compliance (non-conformity)

Administrative Monetary Penalties

⋈ The Weakest Link Doctrine

"It is not enough for mortgage brokers to implement—so must their private lenders."

If your private lenders (individuals or corporations) are not compliant, your entire compliance program is compromised. MQCC® provides the architecture to bring your lenders into conformity.