• Reporting Obligations Related To Terrorist Financing For Registrants and Firms Relying On Registration Exemptions
  • May 7, 2010
  • Law Firm: Borden Ladner Gervais LLP - Toronto Office
  • The Canadian Securities Administrators (CSA) recently published CSA Staff Notice 31-317 Reporting Obligations Related to Terrorist Financing for Registrants, Exempt International Dealers and Exempt International Advisers [available here] regarding monthly reporting obligations and other matters relating to terrorist financing and United Nations Act sanctions on certain countries under the Criminal Code of Canada and related regulations. While the Notice confirms the CSA’s view that the reporting obligations apply to registrants and entities relying on the international dealer exemption and/or the international adviser exemption in National Instrument 31-103 Registration Requirements and Exemptions, we understand that these reporting obligations also apply to firms that rely on other exemptions from registration requirements - for example - the exemption from the exempt market dealer registration requirement that is available in the western provinces and territories. We are seeking clarification from the CSA on this point.