FINTRAC-Aligned · PCMLTFA · Canada

AML/ATF Compliance Training for
Dealers in Precious Metals & Stones

A practical, FINTRAC-grounded program for DPMS businesses in Canada. Complete all five modules and earn your C&G certificate — free.

5Modules

30Questions

~45Minutes

FreeCertificate

Training Modules

// MODULE 01

Who Is a DPMS?

The $10,000 threshold, exemptions, the 90% manufacturing rule, consignment.

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// MODULE 02

Know Your Client

Identity verification, business relationships, beneficial ownership, PEP/HIO screening.

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// MODULE 03

Transaction Reporting

STRs, LCTRs, LVCTRs, the 24-hour rule with worked examples.

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// MODULE 04

Record Keeping

What to keep, the 5-year retention rule, format requirements.

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// MODULE 05

Your Compliance Program

The five pillars, risk assessment, AMPs, and the March 2026 effectiveness standard.

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Please note: This is general AML/ATF awareness education and a marketing resource provided by C&G. The certificate confirms completion of this course only. It is not legal advice and does not, on its own, satisfy a reporting entity's training-program obligations under the PCMLTFA. For a compliance program tailored to your business, contact C&G.

Enter your details to begin

One Step Before You Begin

Enter your name and email to register your spot. Your certificate will be waiting when you complete all five modules.

Your information is collected to issue your certificate and send you relevant C&G compliance resources. We do not sell or share your data. You may unsubscribe at any time.

Registration

// Module 01 of 05 · Page 1 of 3

Who Is a Dealer in Precious Metals & Stones?

Not every business that handles precious metals or stones is automatically subject to PCMLTFA obligations. Understanding the threshold and exemptions is your first critical step.

The $10,000 Threshold — Are You Triggered?

Single $3,500 sale

Below

Single $10,000 sale

Triggered ⚡

$10K inventory purchase

Triggered ⚡

Consignment sale at $12K

Triggered ⚡

Note: The trigger applies to both purchases and sales — including inventory purchases and consignment sales at or above $10,000.

What Counts — Tap to Reveal

Who Is Excluded?

The 90% Manufacturing Rule

Key rule: If manufacturing is less than 90% of all purchases and sales, you are NOT a manufacturer — you are a DPMS subject to full obligations. Findings (clasps, settings) count as manufacturing. Beads and stringing materials do not.

All Exemptions at a Glance

Manufacturers where 90%+ of all purchases and sales are manufacturing activities
Businesses engaged solely in extracting precious metals or stones from a mine
Businesses engaged solely in cutting or polishing precious stones
Jewellery manufacturers selling exclusively to their own employees (not family, not friends)
Goods left with an auctioneer for auction — not treated as consignment

Module 1 · Page 2 of 3

// Module 01 · Quiz

Knowledge Check

Module 1 — 5 Questions

Q1 / 6

At what dollar threshold do PCMLTFA obligations apply to a DPMS business?

Q2 / 6

A jewellery manufacturer generates 85% of revenue from manufacturing and 15% from selling to the public. Are they subject to PCMLTFA obligations?

Q3 / 6

Which of the following is a precious metal under the PCMLTFA?

Q4 / 6

A jewellery manufacturer sells leftover inventory directly to employees. Are these sales subject to PCMLTFA obligations?

Q5 / 6

Goods left with an auctioneer for auction — are they treated as consignment for DPMS threshold purposes?

Scenario · Q6 / 6

Maple Goldsmith Ltd. spends 80% of its purchases and sales on custom manufacturing and 20% on reselling finished jewellery to the public — sometimes above $10,000. Is it a DPMS?

// Module 1 Score

Module 1 · Quiz

// Module 02 of 05 · Page 1 of 2

Know Your Client (KYC)

KYC goes beyond checking an ID. It includes ongoing monitoring, beneficial ownership, third party determination, and PEP/HIO screening.

When Identity Verification Is Required

Cash transactions of $10,000 or more — triggers an LCTR and KYC obligation
Receipt of $10,000+ in virtual currency — triggers an LVCTR
Reasonable grounds to suspect ML/TF — triggers an STR (no dollar minimum)

When a Business Relationship Begins

Trigger

2nd Verification
within a 5-year period

A business relationship begins the second time you are required to verify the same client's identity within a 5-year period. If 5+ years have elapsed since the first verification, the clock resets — the next verification counts as a first again.

Track dates, not just names. A client verified once in 2020 who returns in 2026 is treated as a first-time verification — the 5-year window has elapsed. Your records must show verification dates.

Beneficial Ownership & Third Party — Tap to Reveal

Concept

Beneficial Ownership

Tap to learn →

The Rule

Any individual who directly or indirectly owns or controls 25% or more of an entity. The ultimate owner must be a person — not another corporation.

Concept

Third Party

Tap to learn →

The Rule

If a client acts on behalf of someone else, determine who that third party is and record their information — regardless of whether they are present.

Concept

Ongoing Monitoring

Tap to learn →

The Rule

Once a business relationship exists, monitor transactions for consistency with the client's known profile and keep client info current over time.

Concept

Reasonable Measures

Tap to learn →

The Rule

Ask the client, conduct open-source searches, or consult commercial databases. Document your efforts even if you can't confirm everything — effort must be recorded.

Module 2 · Page 1 of 2

// Module 02 of 05 · Page 2 of 2

PEP & HIO Screening

Who Is a PEP or HIO?

You must take reasonable measures to determine whether a client holds or has held a senior public position. If they do, enhanced due diligence applies.

Foreign PEP

Head of state, minister, general, ambassador, president of state-owned bank, judge of highest court.

Domestic PEP

Governor General, deputy minister, federal/provincial judge, mayor, political party leader, military general.

HIO

Head of an international government organization, its institutions, or an international sports organization.

Family & Associates

Spouse/partner, children, parents, in-laws of PEPs and HIOs are also prescribed family members with elevated scrutiny.

PEP Risk Indicator

Every client should be screened. PEP status can change — a retired politician still requires enhanced scrutiny for a prescribed period.

Module 2 · Page 2 of 2

// Module 02 · Quiz

Knowledge Check

Module 2 — 5 Questions

Q1 / 6

A business relationship begins at which point with a client?

Q2 / 6

What ownership threshold triggers beneficial ownership identification for entities?

Q3 / 6

A mayor of a Canadian city buys $15,000 in bullion. What applies?

Q4 / 6

A client pays cash for diamonds on behalf of their business partner. What must you do?

Q5 / 6

Can a corporation be the ultimate beneficial owner of an entity for PCMLTFA purposes?

Scenario · Q6 / 6

A new corporate customer wants to buy $15,000 of gold bars. The person in front of you is the company's purchasing clerk. What must you do?

// Module 2 Score

Module 2 · Quiz

// Module 03 of 05 · Page 1 of 3

Transaction Reporting Obligations

Knowing which report applies and when is non-negotiable. Missing a mandatory report can trigger significant administrative monetary penalties.

Suspicious Transaction Reports (STRs) — No Minimum Amount

File when there are reasonable grounds to suspect ML/TF. Hover each flag to highlight.

01Client offers to pay significantly above or below market value with no explanation

02Client unusually secretive about identity or transaction purpose

03Multiple cash purchases just below $10,000 by the same or related clients (structuring)

04Client insists on cash and resists other payment methods for large purchases

05Client buys high-value, easily liquidated items with no apparent business purpose

06Third parties appear to be directing the transaction from a distance

Timing: File "as soon as practicable" after forming reasonable grounds to suspect ML/TF. Suspicion — not proof — is the standard.

$0

Min. Amount for STR

Immediate

Listed Entity Report

ASAP

STR Filing Standard

Sanctions Evasion (June 2024)

Report suspected sanctions evasion covering contraventions of the United Nations Act, Special Economic Measures Act, and the Justice for Victims of Corrupt Foreign Officials Act. Sanctions screening must be part of your KYC process. Listed property must be reported to FINTRAC immediately — no grace period.

Module 3 · Page 1 of 3

// Module 03 of 05 · Page 2 of 3

LCTRs & The 24-Hour Rule

Large Cash Transaction Reports (LCTRs)

Trigger

$10,000+ Cash

File when you receive $10,000+ in cash in a single transaction, or when multiple transactions aggregate to $10,000+ within your static 24-hour window. DPMS must also include type, value, and wholesale value of the items sold.

The 24-Hour Rule — Interactive Example

Watch how transactions aggregate within your static window. Click Play to animate.

YOUR WINDOW: 12:00 AM — 11:59 PM

12:00 AM6:00 AM12:00 PM6:00 PM11:59 PM

11:30 AM
$14,000

1:40 PM
$13,000

$27,000

Combined Total — LCTR Required

Your Static Window — You Choose It

Set by You

Any consecutive 24-hour period (e.g. 9 AM Mon to 8:59 AM Tue). Not limited to midnight-to-midnight.

Document It

Must be written into your compliance policies and procedures and declared on every LCTR/LVCTR filed.

Per Business Line

You may use different windows for cash vs virtual currency, but each window must be fixed and documented.

Multi-Location

The rule applies across ALL your store locations. Use one time zone reference and apply it consistently.

Module 3 · Page 2 of 3

// Module 03 of 05 · Page 3 of 3

24-Hour Rule: Worked Examples

Three Aggregation Types

Type 1

Conductor

Tap for example →

Example

Jeremy pays $14K at 11:30 AM and $13K at 1:40 PM. Same conductor, same window. File one LCTR for $27,000.

Type 2

Beneficiary

Tap for example →

Example

Person A pays $6K and Person B pays $5.5K — both for the same beneficiary in the same window. File one LCTR for $11,500.

Type 3

Third Party

Tap for example →

Example

Person A pays $6K on behalf of ABC Corp. Person B pays $5.5K also on behalf of ABC Corp. File one LCTR aggregated on the third party (ABC Corp).

⚠ Watch Out

Window Boundary

Tap for example →

Example

Client pays $6K at 11 PM Monday (Window 1) and $5K at 12:30 AM Tuesday (Window 2). Only 90 min apart but different windows — do NOT aggregate. Consider an STR for the pattern.

Large Virtual Currency Transaction Reports (LVCTRs)

Same 24-hour rule logic applies. Reports must include transaction identifiers and sending/receiving wallet addresses. You may set a separate static window for VC — document both in your policies.

Sub-threshold transactions count. Even transactions under $10,000 individually must be aggregated if together they reach the threshold within your window — and the pattern warrants STR consideration.

Module 3 · Page 3 of 3

// Module 03 · Quiz

Knowledge Check

Module 3 — 5 Questions

Q1 / 6

What is the minimum transaction amount required to trigger a Suspicious Transaction Report?

Q2 / 6

Which correctly describes your static 24-hour window?

Q3 / 6

Same client makes three cash purchases of $4,000 each within your 24-hour window. What do you do?

Q4 / 6

What additional information must a DPMS include in an LCTR that other sectors do not?

Q5 / 6

You find property in your store belonging to a person listed under a UN sanctions order. How quickly must you report to FINTRAC?

Scenario · Q6 / 6

A regular customer who normally buys small items suddenly asks to buy $8,000 in gold coins for cash, and is unusually evasive about the source of funds and nervous about paperwork. The amount is below $10,000. What is the right action?

// Module 3 Score

Module 3 · Quiz

// Module 04 of 05 · Page 1 of 2

Record Keeping Requirements

Records are the evidentiary backbone of your compliance program. FINTRAC requires specific records created and retained in a way that allows timely production.

Minimum Retention Period

Records You Must Keep — Tap Each to Expand

01Large Cash Transaction Records (LCTR)+

02Large Virtual Currency Transaction Records (LVCTR)+

03Information Records+

04Beneficial Ownership Records+

05PEP/HIO & Third Party Records+

Module 4 · Page 1 of 2

// Module 04 of 05 · Page 2 of 2

Format, Access & Practical Advice

Format Requirements

Electronic

Acceptable — must be printable and accessible on demand. Must produce a paper copy when required.

Paper

Acceptable — must be legible and retrievable promptly upon FINTRAC request or production order.

Location

Must be accessible in Canada or retrievable for FINTRAC within a reasonable timeframe.

Production

Must be produced promptly if FINTRAC issues a production order. Organize records for fast retrieval.

C&G Advisory: Inadequate record keeping is one of the most common findings in FINTRAC DPMS examinations. A consistently applied spreadsheet is better than a sophisticated system that nobody uses properly.

Module 4 · Page 2 of 2

// Module 04 · Quiz

Knowledge Check

Module 4 — 5 Questions

Q1 / 6

How long must a DPMS retain its PCMLTFA-required records?

Q2 / 6

What additional information must DPMS businesses include in an LCTR record?

Q3 / 6

Can a DPMS business keep required records in electronic format only?

Q4 / 6

What must a Large Virtual Currency Transaction Record include that a cash LCTR does not?

Q5 / 6

An information record for an individual client must include which elements?

Scenario · Q6 / 6

It has been 4 years since you completed a $20,000 cash sale. A flood destroys your paper files, but you kept scanned copies. A FINTRAC examiner asks for the LCTR records. Are you compliant?

// Module 4 Score

Module 4 · Quiz

// Module 05 of 05 · Page 1 of 2

Building Your Compliance Program

Every DPMS subject to PCMLTFA obligations must implement a written compliance program. It is a living framework — not a filing exercise.

The Five Pillars

// PILLAR 01

Compliance Officer

An individual with sufficient authority to implement the program. In a small DPMS, this can be the owner.

// PILLAR 02

Policies & Procedures

Written methodology outlining your PCMLTFA obligations and the controls you have in place to meet them.

// PILLAR 03

Risk Assessment

A documented review of ML/TF risks specific to your business — clients, products, geographies, channels.

// PILLAR 04

Training Program

Written, implemented ongoing training for all employees and agents. Completing this module contributes.

// PILLAR 05

Two-Year Effectiveness Review

Conducted every two years minimum by an internal or external auditor to test whether your program actually works — not just whether it exists. The March 2026 PCMLTFA amendments introduced an effectiveness standard: a program that does not function in practice will not protect you from penalties.

March 2026: AMPs Increased Up to 40×

40×

AMP Ceiling Increase

Effective

March 2026

Must Work

Effectiveness Standard

What the effectiveness standard means: FINTRAC now assesses whether your program demonstrably functions — not just whether it exists on paper. If your compliance program has not been reviewed since March 2026, that is the first thing to fix. Contact C&G for a two-year effectiveness review.

Module 5 · Page 1 of 2

// Module 05 of 05 · Page 2 of 2

Risk Assessment Framework

Four Risk Dimensions — Tap Each

Risk Type

Client Risk

Tap to assess →

Ask Yourself

Do your clients include PEPs, non-residents, or individuals from high-risk jurisdictions? Do clients pay in cash for large purchases regularly?

Risk Type

Product Risk

Tap to assess →

Ask Yourself

Do you deal in gold bullion, large diamonds, or other high-value easily liquidated items? These are high ML/TF risk products by nature.

Risk Type

Geographic Risk

Tap to assess →

Ask Yourself

Do you source from or sell to clients in FATF grey-listed jurisdictions? Bosnia, Herzegovina, and Iraq were added June 2026. Re-rate your country risk now.

Risk Type

Channel Risk

Tap to assess →

Ask Yourself

Do you accept virtual currency payments? Conduct online sales without face-to-face meetings? These are elevated-risk delivery channels requiring specific controls.

Please note: This module is general AML/ATF awareness education and a marketing resource provided by C&G. The certificate confirms completion of this course only. It is not legal advice and does not, on its own, satisfy a reporting entity's training-program obligations under the PCMLTFA. For a compliance program tailored to your business, contact C&G at candg.ca.

Module 5 · Page 2 of 2

// Module 05 · Final Quiz

Final Knowledge Check

Module 5 — 5 Questions

Q1 / 6

How often must a DPMS conduct a compliance program effectiveness review at minimum?

Q2 / 6

Which is NOT one of the five pillars of a DPMS compliance program?

Q3 / 6

In a small DPMS, who can serve as the compliance officer?

Q4 / 6

What does the March 2026 effectiveness standard mean for your compliance program?

Q5 / 6

A DPMS conducting many online sales without meeting clients face to face — what type of risk is this?

Scenario · Q6 / 6

Your business wrote a thorough AML policy manual two years ago, but no one has used it, staff were never trained, and no risk assessment was done. Under the March 2026 effectiveness standard, where do you stand?

// Module 5 Score

Module 5 · Final Quiz

All 5 Modules Complete!

Generating your certificate...

All 5 Modules Complete

Certificate of Completion

AML / ATF Awareness Training

Canada · PCMLTFA & FINTRAC framework

This certifies that

—

has successfully completed C&G's Anti-Money-Laundering and Anti-Terrorist-Financing awareness course covering ML/TF fundamentals, client due diligence, reporting to FINTRAC, and ongoing monitoring & indicators.

Date

—

Certificate ID

—

Issued by C&G Professional Services Inc.

This certificate confirms completion of an educational awareness course only. It is not legal advice and does not, on its own, satisfy a reporting entity's training-program obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Ready to make your compliance program audit-ready?

This course is awareness training — on its own it does not satisfy your PCMLTFA obligations. Book a free 15-minute consult and we'll show you what a tailored DPMS program looks like.

Book a free 15-minute consult →

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AML/ATF Compliance Training forDealers in Precious Metals & Stones

One Step Before You Begin

Who Is a Dealer in Precious Metals & Stones?

Who Is Excluded?

Know Your Client (KYC)

PEP & HIO Screening

Transaction Reporting Obligations

LCTRs & The 24-Hour Rule

24-Hour Rule: Worked Examples

Record Keeping Requirements

Format, Access & Practical Advice

Building Your Compliance Program

Risk Assessment Framework

All 5 Modules Complete!

AML/ATF Compliance Training for
Dealers in Precious Metals & Stones