INTRODUCTION WHAT IS FINTRAC

Every country in the world, perhaps with a few notable exceptions, is engaged in finding ways to protect the legitimate financial system from those who would abuse it—finding ways to detect and deter and prevent money laundering and terrorist activity financing. When it comes to deterrence and prevention, the work that FINTRAC does to ensure compliance with the law strives to keep illicit funds from entering the legitimate Canadian financial system. This involves ensuring that proper records are kept, that identification is obtained, that risks are being assessed and the other elements of a compliance regime are in place. All the entities that make up Canada's financial system have a stake in ensuring that the level of deterrence is high. Life insurance companies have a stake in this too. When it comes to detection, FINTRAC's intelligence assists investigations, and it assists prosecutions. Financial Intelligence sheds light on the transactions that can be related to criminal activity. It assists investigators in making decisions about where to seek evidence, who to include or exclude as part of the investigation, how the targets are connected and where the assets may be hidden. There are specific legislative requirements under the PCMLTFA -Proceeds of Crime (Money Laundering) and Terrorist Financing Act – that apply to life insurance companies, brokers and independent agents.

Resposibilities of entities in the life insurance industry Agents Agencies MGA’s

Our responsibilities as Insurance Agents - Appointment of Compliance Officer - Written Compliance Policies and Procedures - Risk assessment and mitigation - Review - Reporting - Compliance system - Training

Appointment of Compliance Officer Formal appointment required

Written Compliance Policies and Procedures Updated and reviewed yearly Physical copy highly recommended

Risk assessment and mitigation Used to be a template; new requirement require an essay commenting on risk factors specific to your operation

Review Required yearly Formal findings report required as part of the updated written policies and procedures

Reporting Formal findings report required as part of the updated written policies and procedures

Compliance system Can refer to CF compliance system, must be explicit specified in the policies

Training Can refer to CF training system, must be explicit specified in the policies Record of attendance required