All reporting entities must report suspicious transactions under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) Regulations. On June 10th, FINTRAC released updated Suspicious Transaction Report (STR) guidance on their website (www.fintrac-canafe.gc.ca).
Effective June 1, 2020, an STR must be filed “as soon as practicable after taking measures to establish there are Reasonable Grounds to Suspect (RGS) a transaction is related to the commission of a money laundering/terrorist financing offence.” This replaces the former requirement to report within 30 days of establishing reasonable grounds.
In addition, FINTRAC provides a list of money laundering and terrorist financing indicators for life insurance brokers and companies. These indicators represent the potential red flags which could indicate something may be unusual with a client request or transaction in the absence of a reasonable explanation. The guidance outlines various indicators including characteristics related to: identifying a person or entity, third parties, client behaviours, products and services, patterns and other factors which can help to identify irregularities related to financial transactions.
For those advisors who have drafted their AML programs by using the Canada Life template, an addendum has been prepared to allow you to update your AML/ATF program. In addition, updated wording has been provided that better reflects ID requirements such as authentication and the ability to include electronic images for the dual process method of identifying clients.
You’ll find these changes in the attached addendum. The content in the addendum replaces the same sections in your existing compliance program.
Action required
- Print or save the addendum to your current AMLTF compliance program.
- Indicate the addition of the addendum in Part G – Revision History of your compliance program
Remember,
Good Business is Compliant and Compliance Matters!