The industry is changing, but is your practice keeping up? Be your own compliance officer and keep your insurance offerings up-to-date with regulatory obligations and insurance carrier policies.
Advisors are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations. As required under the Act – which has been in place since October 2000 – an advisor must have an anti-money laundering (AML) compliance regime in place to meet with reporting, record keeping and client identification requirements. The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is an active regulator responsible for auditing advisors to ensure compliance with the Act. Advisors who are audited and found to have no policies in place could be subject to heavy fines.
The required elements of an AML Compliance Regime are:
- appointing a compliance officer – this can be yourself or a member of your staff, but whoever is designated must completely understand Anti-Money Laundering / Anti-Terrorist Financing requirements
- developing written policies and procedures
- assessing the risk to your business by identifying high risk clients and high risk products
- ensuring that you and your staff receive annual AML training either through your own training program or an industry training session
- performing a review of your compliance regime at least every 2 years to ensure that you are up-to-date on any changes in regulations
Not having an AML compliance regime in place can be a costly mistake. FINTRAC is levying heavy fines for non-compliance and have been known to publish details on their website under ‘Administrative Monetary Penalties.’ This is not a place you want to see your name!
For information on how to implement this requirement, Advisors affiliated with PPI can log in to PPI’s advisor websites or the PPI Toolkit to find detailed information on these requirements and sample documents for customization to your practice. Or, for more information, contact us.