DPMS AML/ATF Quick Reference

Canada · PCMLTFA & FINTRAC framework · Dealers in Precious Metals & Stones

Current as of June 2026

1Are You a DPMS?

You buy or sell precious metals, precious stones, or jewellery and engage in a transaction of $10,000+ (cash or otherwise) — purchases and sales both count.
90% manufacturing exemption is all-or-nothing: if manufacturing is under 90% of all purchases & sales, you are a DPMS with full obligations.
Metals = gold, silver, palladium, platinum. Stones = diamonds, sapphires, emeralds, rubies, tanzanites, alexandrites.

2Know Your Client

Verify identity for $10,000+ transactions and whenever required by rule.
Business relationship = the 2nd required ID verification within a 5-year period (clock resets after 5 years).
Beneficial owner = any individual owning/controlling 25%+. Always look through to a natural person.
Do third-party determination and screen for PEP/HIO.

3Reports You May File

STR — reasonable grounds to suspect ML/TF. No $ minimum. File as soon as practicable; never tip off.
LCTR — $10,000+ cash in a single transaction or aggregated in your 24-hour window.
LVCTR — $10,000+ in virtual currency.
LPEP / Terrorist Property — file immediately.

4The 24-Hour Rule

You set your own static 24-hour window — fixed, consecutive, documented, and declared on every report.
Same-client transactions within the window that total $10,000+ aggregate into one report.
Aggregates by conductor, beneficiary, or third party — and across multiple locations.

5Record Keeping

Retain records for a minimum of 5 years.
DPMS LCTRs must capture the type, retail value, and wholesale value of the goods.
Electronic records are fine — you must be able to produce a readable copy on request.

6Compliance Program — 5 Pillars

1. Compliance officer (can be the owner)
2. Written policies & procedures
3. Risk assessment
4. Ongoing training program
5. Effectiveness review — at least every 2 years

!March 2026 — What Changed

Administrative Monetary Penalties (AMPs) increased — non-compliance is materially more expensive.
Effectiveness standard: a program that exists only on paper but does not function in practice is no longer enough to avoid penalties.

Disclaimer: This one-page summary is general AML/ATF awareness education provided by C&G Professional Services Inc. It is not legal advice and does not, on its own, satisfy a reporting entity's obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Always confirm current requirements with FINTRAC guidance.

Need a compliance program tailored to your business? Book a free 15-minute consult → candg.ca/contact