What CJA Members Need to Know
In 2026, Canadian jewellers continue to face increased screening from banks and the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Canada’s anti-money laundering (AML) regulator, regarding compliance. Some jewellers recently received letters from their financial institutions requesting evidence of their AML compliance programs, including evidence of the Compliance Officer’s appointment, policies and procedures, a documented risk assessment, training, and the past two years’ reviews (audits). While these requests may seem innocuous, failure to provide a satisfactory response can lead to bank accounts being closed. What’s more, the timeframes to respond to such requests are often short.
If you receive a similar request, the first step is to determine whether your business is considered a Dealer in Precious Metals and Stones (DPMS) under Canadian AML legislation. Most businesses that sell precious metals or stones, including jewellery, whether as part of retail or wholesale operations, are DPMSs. There are very few exceptions, which are described on FINTRAC’s website.
Under Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and regulations (we’ll refer to this as AML requirements from this point on), DPMS must maintain an AML compliance program that incorporates five key elements:
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- A formally appointed Compliance Officer, a senior person who is responsible for oversight;
- Written AML policies and procedures tailored to your business;
- A documented risk assessment, including a methodology, risk ratings, and measures to address higher-risk areas;
- An ongoing compliance training program with supporting records; and
- A Compliance Effectiveness Review (also called a two-year review or audit), completed at least every two years.
Here’s How CJA and Outlier Can Help
CJA has tools for members, including free online, on-demand tools, access to training webinars, and discounted services from our expert partners at Outlier Compliance Group for members who want a more hands-on approach.
How to Access Your Complimentary CJA AML Wizard
CJA members have complimentary access to Outlier’s online AML Wizard (valued at $2,000), which can help you prepare or update your AML Policy and Procedures and Risk Assessment.
Here is how to access the AML Wizard
- For New Accounts: contact the CJA Office to create a new account at: info@canadianjewellers.com
- For existing members, log in to: Login Outlier Solutions. If you have forgotten your password, select Forgot Your Password to reset it.
- Once logged in, click on “Your Account” at the top right of the webpage.
- Your available and completed documents will appear under the heading for “Purchased Documents.”
- Click on “Use Wizard” located beside the Policy and Procedures or Risk Assessment. You will then be guided through a series of questions about your business.
- Once the questions are completed, select “Download Customized Document” to download yourcompleted document.
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The Wizard is a useful starting point; however, members who use the AML Wizard should ensure it is complete, robust, tailored to their business, and aligned with actual processes (what you’re actually doing).
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Need Additional Assistance?
For assistance accessing the Wizard or reviewing your AML requirements, please contact the CJA or
Outlier Compliance Group at info@canadianjewellers.com
If you require a more hands-on approach, including developing a customized AML Compliance Program, responding to bank or FINTRAC requests, or completing the required two-year Compliance Effectiveness Review, you can contact Outlier Compliance at info@outliercanada.com. CJA members also have access to preferred pricing on eligible Outlier services.
