Guidelines for Compliance with Canada s Anti-Money Laundering and Terrorist Financing Regime

Transcription

1 Guidelines for Compliance with Canada s Anti-Money Laundering and Terrorist Financing Regime Updated January 2012

2 Contents An Introduction to FINTRAC... 3 Understanding FINTRAC Obligations... 4 Mandatory Reporting to FINTRAC Suspicious transaction or attempted transaction reporting (STATR) Large Cash Transaction Record Terrorist Group or Listed Person Property Report... 5 Interacting with FINTRAC Suspicious Client Activities that Result in Reporting... 5 Reporting Timelines for Suspicious Transactions or Attempted Transactions... 6 Reporting Guidelines FINTRAC-Imposed Audit of either Agent or Agency... 7 What to Expect During an Audit... 7 Ensuring FINTRAC Compliance... 8 Politically Exposed Foreign Person (PEFP) Record... 9 Highlights from the 2008 CLHIA Guidance Manual Understanding Money Laundering FINTRAC Stages of Money Laundering Indicators of Suspicious Transactions or Attempted Transactions - Industry Specific (STATR) Scenarios of Suspicious Life Insurance Transactions or Attempted Transactions National Best Forms Checklist of Requirements AML Risk Matrix - Documenting & Assessment of Risk AML Risk Matrix - Client Anti-Money Laundering, Anti-Terrorist Financing Training Sign-in Sheet Compliance with Canada s AML / ATF Regime Page 2

3 An Introduction to FINTRAC Changes to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act became effective June 23, Visit for full details. The objectives of the Act are: to help detect and deter money laundering and the financing of terrorist activities and to facilitate investigations and prosecutions of money laundering and terrorist activity financing offences. FINTRAC is an independent financial intelligence unit, operating independently from law enforcement agencies such as the RCMP. They have a dual mandate: 1. To facilitate more effective and efficient recognition of money laundering and/or terrorist activity financing, and 2. To conduct their own internal research and obtain information from other international sources. Because FINTRAC is also responsible for ensuring life insurance agents and brokers comply with the Act, they have the authority to inquire into your business and examine your records to ensure compliance with the Act. As an independent insurance Agent or Agency working directly with the public, you are considered to be in a front-line position to detect Money Laundering (AML) and Terrorist Financing (ATF) situations. Each National Best member must ensure he or she is aware of, and complies with, the obligations under the AML/ATF Regulations. It is your responsibility to ensure that you have appropriate procedures in place and that you are prepared in the event you are audited by FINTRAC staff. For more information or details regarding your obligations, we encourage you to visit the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) at Some of the changes that affect your business are: Client identification requirements Source of funds Third-party determination Suspicious transaction reporting Development of AML/ATF procedures Auditing compliance Enforcement of procedures as laid out in the Act Compliance with Canada s AML / ATF Regime Page 3

4 National Best is committed to assisting you in your own personal and financial protection, and the protection from others who may attempt to use your legitimate business to fund illicit practices. This manual outlines what you need to know, and what you need to do, to protect yourself and your business, and abide by the regulations as set out in the Act. Understanding FINTRAC Obligations The Act requires all Brokers to adopt a compliance regime and ensure that all employees and those who act on their behalf comply with the Act. According to FINTRAC, our compliance regime needs to be tailored to fit each agency s business needs. It should also reflect the nature, size and complexity of the entire organization. The Act s five requirements include, and are covered within this manual: 1. Appointing a compliance officer (the compliance officer should be someone senior, in a decision-making role within the management team) 2. Developing detailed written, auditable compliance policies and tested procedures for reporting and record-keeping 3. Ongoing review of the effectiveness of the compliance program through selfassessments and/or audits 4. Compliance training for employees, Brokers, or others acting on behalf of your Agency plus an ongoing training plan (evidence must be provided that you and your staff review the training program and update as necessary) 5. Assessing and documenting the money laundering and terrorist financing risks unique to your business. Risk mitigation is about implementing controls to limit the potential money laundering and terrorist financing risks you have identified stay within your risk tolerance level. In 2008, CHLIA published its Guidance Manual to Combat Money Laundering and Terrorist Activity Financing. National Best used this manual to develop its organizational protocol and provide agency owners, managers and associates with the tools they need to ensure compliance with the Act. The entire CHLIA Manual is available on the National Best website at C-CHLIA2008.pdf. Mandatory Reporting to FINTRAC The Act has three sections that outline mandatory reporting requirements: 1. Suspicious transaction or attempted transaction reporting (STATR) 2. Large cash transactions reporting, and 3. Terrorist group and listed person property reporting Compliance with Canada s AML / ATF Regime Page 4

5 1. Suspicious transaction or attempted transaction reporting (STATR) You are required to submit a STATR report if you have reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist activity financing. You are expected to use your judgment when reporting. See the following section on Interacting with FINTRAC for guidance, and discuss the file with your agency owner and compliance officer prior to reporting. Several possible descriptive scenarios are listed later in the manual that can assist with determining if activity is suspicious. 2. Large Cash Transaction Record National Best does not accept cash currency as payment for product. We expect additional documentation for payments over $10,000 received in a single transaction from a financial entity that is not a bank, credit union or trust company, or a public body. Please discuss record keeping with the compliance officer. 3. Terrorist Group or Listed Person Property Report Property is defined as any type of real or personal property. Examples include cash, bank accounts, insurance policies, money orders, real estate, securities (including mutual funds), and traveler s cheques. You are legally obligated to report if you have property in your control that you know is owned or controlled by or on behalf of a terrorist group or listed person. This includes attempted transactions. Reports must be sent by paper. Interacting with FINTRAC You may become involved with FINTRAC protocols in one of two ways: 1. Client activities seem suspicious and a report is filed with FINTRAC; or 2. FINTRAC determines they need to complete an audit on your business activities. You need to be prepared for both. 1. Suspicious Client Activities that Result in Reporting There are four possible scenarios and your course of action depends on which set of circumstances is present. In all cases, if you have been involved in a life insurance transaction you may have a reporting obligation to FINTRAC and under the Criminal Code. If you have not been involved in a life insurance transaction, then your only potential reporting obligation will be under the Criminal Code. Compliance with Canada s AML / ATF Regime Page 5

6 Scenario 1 - If you do not know that the property in your possession or control is terrorist property and you do not suspect that it is, there is no obligation to report to FINTRAC under the Act or under the Criminal Code. Scenario 2 - If you do not know that the property in your possession or control is terrorist property but you suspect that it is, there is no obligation to file a Terrorist Group or Listed Person Property Report to FINTRAC under the Act or disclose it to the RCMP and CSIS under the Criminal Code. In this circumstance you will have to file a Suspicious Transaction or Attempted Transaction Report regarding such property. Scenario 3 - If you have property in your possession or control that you know is owned or controlled by or on behalf of a terrorist group or listed person, including information about any transaction or proposed transaction relating to that property, AND you have been involved in a life insurance transaction, you must file a Terrorist Group or Listed Person Property Report to FINTRAC and disclose it to the RCMP and CSIS under the Criminal Code. Scenario 4 - If you have property in your possession or control that you know is owned or controlled by or on behalf of a terrorist group or listed person, including information about any transaction or proposed transaction relating to that property, BUT you have not been involved in a life insurance transaction, you must disclose it to the RCMP and CSIS under the Criminal Code. Descriptive scenarios can be found later in the manual. Reporting Timelines for Suspicious Transactions or Attempted Transactions You have thirty (30) days from the date on which you have reasonable grounds to suspect that the transaction or attempted transaction is related to a money laundering or terrorist activity financing offence to file your report. If suspicion occurs at the time of the transaction or attempted transaction, the 30-day reporting timeline begins at that time. If the suspicion occurs after the transaction or attempted transaction or after multiple transactions or attempted transactions, the 30-day reporting timeline begins at that later time. Reporting Guidelines 1. You are not permitted to tell the client that you have made a report. FINTRAC will send National Best an acknowledgement message when your report has been received electronically. This will include the date and time your Compliance with Canada s AML / ATF Regime Page 6

7 report was received and a FINTRAC-generated identification number. If your report contains incomplete information, FINTRAC may contact you by phone, or you can file an updated report using the identification number assigned to the original report. This process must be completed within the 30-day time period. Your obligation to report is not considered fulfilled unless the report is complete. 2. Liability in relation to reporting STATR to FINTRAC. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act states that no criminal or civil proceedings lie against a person or an entity for making a report in good faith. In other words, you cannot be sued for disclosing information to FINTRAC as long as the report has been made in good faith. Failure to file a STATR carries a maximum $2 million fine and allows up to five years imprisonment. 2. FINTRAC-Imposed Audit of either Agent or Agency What to Expect During an Audit Questionnaire: You will receive a letter with instructions to complete an online questionnaire. There is a 30-day time period to complete the questionnaire. admin@nbbn.ca should be provided a copy of this questionnaire if/when you are contacted by FINTRAC staff. Audit: If you are selected for an audit, you will need to provide FINTRAC with a copy of the following: Compliance policies and procedures Reporting policies, procedures and protocols Training program for staff and or brokers Risk assessment for money laundering and terrorist financing Any external review from past audits and your agency s action plan response Organization chart (see Registered Agent list on our website) List of all non-registered investment cases for the previous 12 months Any large cash transaction records Access to all client information and records Audit follow up: After the initial audit, you can expect the following: Compliance with Canada s AML / ATF Regime Page 7

8 Deficiency Letter: You will receive a letter 30 to 45 days after the audit which will outline any deficiencies. It will request that you submit an action plan within 30 days to address all deficiencies identified. Please copy this to admin@nbbn.ca for creation of the Action Plan Response. Action Plan Response: You will be required to submit an action plan addressing the deficiencies identified in the audit. Your action plan should provide a timeline which identifies the planned implementation of any required changes to your procedures. Ensuring FINTRAC Compliance We ensure compliance with the Act through our documents known collectively as Client Information Records. Annual reviews with clients help to ensure client information is kept current. According to the Act, if your client pays $10,000 or more through the purchase of an annuity or life insurance, either at the time of sale or will deposit more than $10,000 into the product over its duration, you must retain a Client Information Record. National Best obtains the information necessary for the Client Information Record on its Know Your Client form and other documentation as required by the situation. If your agency does not use the Know Your Client form, use the following table to ensure your information is compliant. Be sure your agents verify identification. Signed copies of the forms may be kept electronically, provided a paper copy can be made at any time. Records must be maintained for at least five years from the date they were created, or five years from the date of the last transaction. For clients not physically present at the purchase of a product, paying by credit card ensures a tracking of his or her Canadian credit history. What is a Client Information Record? Individual Client Client name Address Date of birth Nature of principal business or occupation Proof you have verified client identity using valid, unexpired documentation including: o Birth certificate o Driver s license o Provincial health card (where allowed) Compliance with Canada s AML / ATF Regime Page 8

9 o Passport o Any similar record, other than client SIN Record the type of ID viewed, its reference number and place of issue Corporate Client Certificate of corporate status (ascertain the existence, name and A record that the corporation is required to file annually under the applicable provincial securities legislation; or address of the corporation, and the Any other record that ascertains its existence as a corporation names of its directors) Keep a record of the name and occupation of all directors of the corporation and the name, address and occupation of all persons who own or control, directly or indirectly, 25 per cent or more of the shares of the corporation. Non-Corporate Client Confirm its existence by reference to a partnership agreement, articles of incorporation, or other similar documentation Keep a record of the name, address and occupation of all persons who own or control, directly or indirectly, 25 per cent or more of the non-corporation entity. Not-for-profit Documentation that confirms the entity is: Corporation o A charity registered with CRA o An organization that solicits charitable financial donations from the public Third-Party Written statement must include: Determination Record Individual and third party s name, address, date of birth and nature of principal business or occupation The nature of the relationship between the third party and the individual If unable to determine the third party but suspect that there is involvement, a signed statement from the individual stating they are not acting on behalf of a third party must be signed Politically Exposed Foreign Person (PEFP) Record A Politically Exposed Foreign Person (PEFP) is a person who has held or holds one of the following positions in a foreign state: Head of state or head of government Member of Executive Council of government or member of legislature Deputy minister or equivalent rank Ambassador or Attaché or Counselor of an Ambassador Compliance with Canada s AML / ATF Regime Page 9

10 Military officer with rank of general or above President of a state-owned company or a state-owned bank Head of government agency Judge Leader or president of a political party represented in legislature Holder of any prescribed office or position Additional documentation for PEFP must be retained in your client file: The office or position held with respect to the person initiating the transaction The source of funds that are used for the transaction The date you determined the person is a PEFP The name of the person who conducted a senior review of the transaction The date the transaction was reviewed The prescribed family members of a politically exposed foreign person are: a) The person s spouse or common-law partner b) A child of the person c) The person s mother or father d) The mother or father of the person`s spouse or common-law partner, and e) A child of the person`s mother or father Please use the National Best Politically Exposed Foreign Persons Form if any of the above is present. Highlights from the 2008 CLHIA Guidance Manual The entire manual is important to us and to our industry. All National Best agents must attend training on FINTRAC, read and accept the CLHIA Manual as stated on p. 22 of that manual. The following are some highlights that are beneficial for general understanding of money laundering and its impact: Understanding Money Laundering Money laundering is defined as any act or attempted act to disguise the source of money or assets derived from criminal activity. Essentially, it is the process where dirty money is transformed into clean money. Under Canadian law, a money laundering offence occurs when property such as money is used, and that property (money) came from the commission of another offence (such as drug dealing or fraud). FINTRAC Stages of Money Laundering The process of money laundering is ongoing. Dirty money is constantly being introduced into the financial system in an effort to clean it. There are three recognized stages in the money laundering cycle that are common to our industry. Compliance with Canada s AML / ATF Regime Page 10

11 Placement is the initial stage in which money from criminal activities is placed in financial institutions. One of the most common methods of placement is structuring or smurfing, which is the breaking up of currency transactions into portions that fall below the reporting threshold for the specific purpose of avoiding reporting or record keeping requirements. Because most life insurance companies in Canada do not accept cash payments, you should watch for cash equivalents, such as money orders or traveler s cheques. Layering is typically the second stage where the process of conducting a complex series of financial transactions is executed with the purpose of hiding the origin of money from criminal activity and hindering any attempt to trace the funds. This stage can consist of multiple securities trades, purchases of financial products such as life insurance or annuities, mortgages, cross-border transactions and wire transfers. Integration is the final stage. It involves placing the laundered proceeds of crime back in the economy to create the perception of legitimacy. For example, the money launderer becomes the beneficial owner of a legitimate business enterprise. In outward appearance, it is a normal commercial entity. In reality, its whole operation is based on criminal money. These stages can occur simultaneously, separately, or can overlap. Indicators of Suspicious Transactions or Attempted Transactions - Industry Specific (STATR) The following is a sample of some industry-specific indicators that might lead you to suspect that a transaction is related to a money laundering or terrorist activity financing offence. It will not be just one of these factors alone, but a combination of several factors in conjunction with what is normal and reasonable in the circumstances of the transaction or attempted transaction. What to Watch for: Client proposes to purchase a life insurance product using a cheque drawn on an account other than his/her personal account. Client requests an insurance product that has no discernible purpose and is reluctant to divulge the reason for the investment. Client who has other small policies or transactions based on a regular payment structure makes a sudden request to purchase a substantial policy with a lump payment. Client conducts a transaction that results in a conspicuous increase in investment contributions. Client cancels investment or insurance soon after purchase. Compliance with Canada s AML / ATF Regime Page 11

12 Client shows more interest in the cancellation or surrender than in the long-term results of investments. Client makes payments in cash, uncommonly wrapped notes, with postal money orders or with similar means of payment. The duration of the life insurance contract is less than three years. The first (or single) premium is paid from a bank account outside the country. Client accepts very unfavorable conditions unrelated to his/her health or age. For further examples, see Descriptive Scenarios of Suspicious Life Insurance Transactions or Attempted Transactions. Scenarios of Suspicious Life Insurance Transactions or Attempted Transactions Scenario 1 No Picture ID A potential customer meets with you to purchase a life insurance policy or an annuity. You ask the person for a Driver's Licence or Passport. The potential customer shows a "passport" with no picture and when questioned by you states that it is a military passport and that military passports do not have pictures. When asked for another form of ID, the person, unable to produce another ID, becomes irate and questions whether the insurance company wants her business or not. Scenario 2 Change in Payment Behaviour You notice that for the third Friday in a row a small business owner gave you a payment of exactly $9,500 in money orders to add to his individual variable insurance contract. Scenario 3 High-Risk Business A jeweler/precious metal dealer applies for a corporate owner life insurance policy. In accordance with due diligence procedures for owners in high risk businesses, the dealer provides valid articles of incorporation and documents that verify its identity is accurate and complete. You notice that on the first of every month, the dealer calls in requesting a loan, which is immediately paid back with cash equivalents. Scenario 4 Disregard for Monetary Losses An annuity owner calls you to request a surrender of an annuity, which was held for less than one year. When you apprise the owner of the surrender charges and potential losses, the owner indicates that the fees and losses do not matter and to please make the surrender immediately and wire the money to an account located in Europe. Scenario 5 Foreign Clients and Overseas Markets On taking care of business, you heard that two of your clients are currently residing in North Korea. You also know that the address of record of both clients is in your province. Both contracts have been in force for approximately 10 years. Upon further investigation, you learn that one client is currently in North Korea but the owner of the policy resides in Compliance with Canada s AML / ATF Regime Page 12

13 your province. The other client, who is the owner and insured of her policy, is also currently living in North Korea. Both policies were issued in Canada and premiums are being paid via electronic bank drafts with funds from Canadian credit unions. Scenario 6 Know Your Customer You have written an application for life insurance and the client provides payment to you in the form of eighteen money orders totalling $9,088, ranging from $88.00 to $1,000 in amount. The prospective insured is a 25-year old male who does not have a chequing account. The application shows Columbia as country of birth, and a current address in another province. The application also indicates that the proposed insured is the business owner of a Columbian restaurant in your own community. Scenario 7 Suspicious Transaction Monitoring You receive what appears to be a $15,000 bank draft from Tulips Bank in The Netherlands for payment of insurance premiums. The insured's name and policy number are written on the cheque, which appears to be in U.S. dollars. The name of a not-forprofit organization is printed toward the bottom of the cheque. Scenario 8 Crime Connection Awareness You become aware through the media that a long-standing client was involved in organized crime activities in a foreign country. The insurance policies were of 29 years duration. One provided for a payment of close to $1 million in case of death. The other was a Universal Life product with value of over half this amount. Scenario 9 Use of Cooling-off Period You discover an instance where the single life insurance premium has been paid in Canadian currency and the request for a refund under the 10-day free look is to be paid in another currency. Scenario 10 Corrupted Information A client is being referred to you by an insurance company employee with the information that payment for the policy will be made by two separate wire transfers from overseas accounts because the funds used for payment are the proceeds of overseas investments. The employee indicates that the client is well known to the insurer, there are no reasons for concern, and strict compliance need not be adhered to in this case. Scenario 11 Multiple Policies In taking care of business, you find out that a client has purchased life insurance policies from a number of insurance companies. In every case, the insurer was requested to provide life coverage with an indemnity value identical to the premium. There were also indications that in the event that the policies were to be cancelled, the return premiums were to be paid into a bank account in a different jurisdiction to the insured. Scenario 12 Insurance Exceeding Needs Compliance with Canada s AML / ATF Regime Page 13

14 After you have done a thorough life insurance needs analysis, the client insists on buying twice the needed amount for greater financial security. In discussing coverage and payment, you notice that he shows more interest in the cancellation or surrender than in long-term coverage. Scenario 13 Repeated Beneficiary Changes You are contacted by a potential client who wants to buy life insurance of less than three years duration. Three months after the establishment of the policy, the beneficiary is altered. The policyholder calls you again two months before the expiry of the insurance for another beneficiary change. The insured remained the same. Scenario 14 Knowledgeable Customers In purchasing an annuity, the client appears to be very conversant with money laundering or terrorist activity financing issues and she is quick to volunteer that the funds are "clean". She goes on to say that annuity products are well suited to "layering". Scenario 15 Special Favours Offering While providing life insurance advice, the client offers you money, gratuities or unusual favours for the provision of services that may seem unusual or suspicious such as sending correspondence to an address other than his home address, insisting that the transaction be done quickly or establishing identity using something other than his personal identification documents. National Best Forms Our forms are an essential part of ensuring FINTRAC compliance because the forms have been designed to ensure all information needed by FINTRAC is compiled and updated. The forms we use are: The Know Your Client form The New Client Disclosure form The Politically Exposed Foreign Persons form The Leverage Disclosure form The Verification of Identification and Third Party Determination form Compliance with Canada s AML / ATF Regime Page 14

15 Checklist of Requirements Agency Owner / Agency Manager / Advisor Office Or Outside General Agency Office: Requirement Use National Best Compliance Officer Written AML / ATF policies & procedures created, or adopt National Best Guidance Manual Risk mitigation strategies for identified high risk areas created within Guidance Manual Staff / other advisors trained on AML / ATF obligations (documented attendance) and attendance sheet (in manual) submitted to Compliance Officer Documented procedures for identifying and reporting suspicious or attempted suspicious transactions Review process for AML / ATF policies & procedures (minimum every 2 years) Hold copies of signed p 22 forms for all associates that have completed FINTRAC training In case of audit, expect written report from AML / ATF policies & procedures review Develop action plan to implement needed changes to AML / ATF policies post audit Date and location completed Head Office: Requirement Hold copies of signed p 22 forms for all associates that have completed FINTRAC training Review all insurance policies in suspicious cases prior to submission for FINTRAC compliance Keep copies of FINTRAC training attendance sheets Date and location completed Compliance with Canada s AML / ATF Regime Page 15

16 AML Risk Matrix - Documenting & Assessment of Risk Product Risk Factors Sample Risk Mitigation High Product has investment features enabling it to accumulate cash Products can store cash value When the risk is considered to be high you must adopt written policies and procedures for: Ownership can be easily Identifying the client(s); transferred Ease of withdrawal Keeping records, including keeping reasonable High placement risk - ease and measures to keep client information up to date; frequency of deposits and Monitoring life insurance withdrawals transactions; Conduct ongoing monitoring to detect transactions that are reportable to FINTRAC; Mitigate the risks identified as appropriate. Medium Product may have some features of high risk products, but also has built in limitations restricting access or availability on deposits or withdrawals, significant surrender charges, etc. When the risk is considered to be medium you must adopt written policies and procedures for: Identifying the client(s); Conduct ongoing monitoring to detect transactions that are reportable to FINTRAC; Mitigate the risks identified as appropriate. Low Product that has no investment features or no features of stored value or transferability Restrictions on availability on deposits and/or withdrawals Exempt under local regulations No high risk features When the risk is considered to be low, you must consider written policies and procedures for: Identifying the client(s); Conduct ongoing monitoring to detect transactions that are reportable to FINTRAC; Mitigate the risks identified as appropriate. Compliance with Canada s AML / ATF Regime Page 16

17 Wealth Products Product Deferred Annuity Non-Registered (example: Segegrated Funds) Deferred Annuity Registered Immediate Annuity Non-Registered Immediate Annuity Registered Written Risk Strategy Insurance Products Universal Life Whole Life with Side Account Whole Life without Side Account Term Insurance Living Benefits Group Pensions Registered Pensions Plans Retirement Savings Plans Deferred Profit Sharing Plan ESP/EPSP ** can our advisor sell this as a product Registered Investment only Non-Registered Investment Tax Free Savings Plan Group Benefits Basic & Optional Life Paid Up Life Survivor Income Basic & Optional AD&D Basic & Optional Long Term Disability Weekly Income Extended Health Care Dental Financial Arrangement *pooled Financial Arrangement *refund accounting Financial Arrangement *Admin services only Disability Consulting /Claims Management Personal Benefits Compliance with Canada s AML / ATF Regime Page 17

18 Third-Party Administrator Products Term Life & Accident & Sickness Travel Insurance Medical Coverage (health & dental) Other Distribution Channels Other Delivery Channels AML Risk Matrix - Client High Risk Medium Risk Low Risk Geographic area outside of your normal practice New client, limited relationship Politically Exposed Foreign Person (PEFP) Non-resident Alien Source of funds is high risk activity (casino/car dealer/pizza franchise or other high risk occupation) Entities with multiple layers of ownership not easily distinguished Existing client Domestic Politician Any client reluctant to disclose source of funds or provide ID Questions regarding surrender/free look period Overpayment of deposit Geographic area within the area of your normal practice Long term client, significant relationship Source of funds is not considered high risk Payment by cheque/wire Full disclosure Compliance with Canada s AML / ATF Regime Page 18

19 Large Cash Payments Structured Cash Payments Questions regarding surrender/free look Overpayment of deposits & subsequent refund Refusing to divulge source of funds or to provide ID Politically Exposed Foreign Person or High Risk fund source who provides ID immediately along with full disclosure and meets suitability for product No suspicious activities Compliance with Canada s AML / ATF Regime Page 19

20 Anti-Money Laundering, Anti-Terrorist Financing Training Sign-in Sheet Date of Presentation: Location of Presentation: Presenter: First Name Last Name Signature Compliance with Canada s AML / ATF Regime Page 20