FINTRAC’s P2P Information Sharing guidance allows reporting entities to share personal data without consent under an approved code of practice to enhance ML/TF and sanctions-evasion detection 

This information sharing is governed by an approved code of practice, submitted to FINTRAC and the Privacy Commissioner, which sets out the types of data that can be shared, secure methods for transmission, and safeguards including access controls, encryption, breach response, and data retention policies. Exchanges can only occur between entities within the same approved code, which must be renewed or updated at least every five years, enabling organizations to gain a fuller picture of client activity and more effectively identify suspicious behaviour…