Phase II Anti-money laundering reforms - Business Compliance Impacts [pdf, 495 KB]
...transactional volumes compared to Phase I businesses. Suspicious transaction reporting by HVDs can put them potentially at increased risk of disclosure (to criminals) than is currently the case for Phase I entities or other Phase II entities. Protecting the identity of real estate agents or pawn brokers who may submit an STR that results in an investigation and prosecution may require other ‘checks and balances’ driving up costs. Lower STR reporting assumed for P...