On October 13, 2023, the Office of the Superintendent of Financial Institutions (“OSFI”) issued a draft Integrity and Security Guideline (the “Guideline”) further to recent changes enacted through Bill C-47, the Budget Implementation Act, to require federally regulated financial institutions (“FRFIs”) to “have and adhere to adequate policies and procedures to protect themselves from threats to their integrity and security, including foreign interference”, starting on January 1, 2024.
Comments on the Guideline are due November 24, 2023. The OSFI intends to issue a final Guideline by end of January 2024.
Expectations under the Guideline are to “are to be applied on a proportional basis” based on a FRFI’s ownership structure; strategy and risk profile; and scope, nature, and location of operations.
Definition of Key Terms
The Guideline defines certain key terms, including “integrity”, “security”, “foreign interference” and “undue influence.” Each of these terms is defined broadly, with the definitions only stating what each “includes” and not purporting to be a comprehensive definition.
- “Integrity” is defined as including “actions,…
