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January 25, 2011

Anti-Money Laundering Review

As you may know, all life insurance companies, brokers or independent agents must apply specific measures to comply with Anti-Money Laundering (AML) legislation. It is important that we review these requirements with you so that transactions are processed without delay. The AML Legislation requires that we:

• Identify clients within 30 calendar days following the account opening and keep the related records on file. It is essential that you confirm the identities of the persons whose signatures appear as the Policyholder(s) / Owner(s) by examining the original government-issued identification provided by the client and by verifying the signature on the application. Details on how to perform client identification can be found in the following documents:
  
  Record Keeping and Client Identification requirements when the client is an Individual.
  
  Record Keeping and Client Identification requirements when the client is a corporation or an entity other than a corporation.
  
  
• Determine whether the client is acting on behalf of a third party. If a third party is identified the Third Party Determination form (PC 5097) must be completed and submitted with the application.
• Take reasonable measures to determine whether you are dealing with a Politically Exposed Foreign Person (PEFP). When a client makes a lump sum payment or deposit of $100,000.00 or more, you are required to complete section 3 of the Client Identification - Supplementary Information Form (Form 6330). Additional details regarding this requirement can be found in the document: Politically Exposed Foreign Person Determination.
• Take measures to conduct an assessment of the money laundering and terrorist financing risks in the course of the client’s business activities. Standard life may require additional information about a client in order to comply with AML legislation, for example, the source of the funds, additional information about a corporation to substantiate the client identification, more details about the ownership structure of a corporate client or additional information to verify the identity of the owners and directors of the corporation, etc.

If the identity of the client cannot be established within the required time frame, Standard Life may place a stop transaction on the account until we receive proper identification.

For more detailed information about your obligations to comply with Anti-Money Laundering legislation, please refer to the following links:

Standard Life - Compliance Website

Financial Transactions and Reports Analysis Centre of Canada - FINTRAC

Industry Specific Information Sheet - Life insurance companies, brokers or independent agents - Legislative requirements effective June 23, 2008


As a reminder, here are some messages that we had prepared on this subject in 2008:

Importance of client identification

Record keeping and client identification

Politically Exposed Foreign Person Determination