Consultation Paper: Strengthening Canada s Anti-Money Laundering and Anti- Terrorist Financing Regime

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1 30 Eglinton Avenue West, Suite 306 Mississauga ON L5R 3E7 Tel: (905) Website: March 1, 2012 Leah Anderson Director, Financial Sector Division Department of Finance 140 O Connor Street Ottawa ON K1A 0G5 Submitted by Dear Ms Anderson: Subject: Consultation Paper: Strengthening Canada s Anti-Money Laundering and Anti- Terrorist Financing Regime Independent Financial Brokers of Canada (IFB) welcomes the opportunity to contribute to this consultation. We consent to the public posting of this submission in its entirety on the Department of Finance s website, including the name of our association and the signatory. IFB is a professional, not for profit trade association representing approximately 4,000 licensed financial advisors across Canada. Our membership is comprised of self-employed and generally small business owners or sole proprietors who operate as independent contractors with the companies they do business with. They have chosen this model so they can offer clients a variety of financial products from various companies. Many hold multiple financial licenses to enable them to provide clients with advice and access to a wide range of products including mutual funds, securities and life insurance products, such as term and universal/whole life policies, segregated funds, annuities, etc. IFB supports the professional standards of its members by providing a comprehensive errors and omissions program, compliance advice and tools, sponsoring continuing education events and adherence to our code of conduct. IFB supports the Canadian government s commitment to be a strong contender in the global fight against having legitimate financial systems used for criminal activities, such as money laundering, terrorist financing and other illegal purposes. While we applaud this commitment, we are concerned that the application of the proposals under consideration will significantly

2 increase the scope of the current AML/ATF compliance practices, well beyond those intended to identify and deal with higher risk situations. Of particular concern is that any new requirements will apply equally to all reporting entities, whether they are large financial institutions or small even individual financial businesses, like our members. IFB responded to the Department of Finance in December 2011, regarding proposed amendments to the regulations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). At that time, we stated our over-riding concern that the increasingly onerous obligations for reporting entities under this Act are no longer tied to identifiable higher risk situations. This represents a fundamental shift in the focus of this legislation such that compliance is becoming an increasingly prescriptive exercise. The premise of risk based legislation is that it allows those it regulates to concentrate on identifying and reporting financial transactions or customers that are suspicious or high risk. This is generally viewed as being compatible with the cost of establishing the policies, procedures, compliance and tracking systems needed for this purpose. It also recognizes that the vast majority of individual and business financial transactions conducted in Canada are legitimate. However, if the full suite of proposals being suggested is implemented, financial reporting entities (whether large complex institutions or individually licensed advisors) will be responsible for overseeing and maintaining records for virtually every transaction. This represents a huge cost to the industry with no corroborative evidence that such oversight is required in the Canadian marketplace. We believe it is incumbent on the Government to tie the deficiencies identified by the Financial Action Task Force (FATF) more directly to the Canadian experience before enacting these changes. This burden becomes even more apparent when viewed in relation to individual life insurance brokers who are reporting entities under the Act and subject to many of the proposals. The Act has been in place for over 12 years now and Canadian regulators have sound experience on which to assess its success and base the need for new regulations. IFB believes that this review of the Act presents an excellent opportunity for the Government to revisit some of the existing requirements, particularly as they pertain to independent life insurance brokers. While we presented much of the following argument in our December 2011 response to regulatory changes, we are reiterating it for consideration and discussion. Independent life insurance brokers are reporting entities and required to have an individually documented Compliance Regime - Under the PCMLTFA, independent life insurance brokers are reporting entities. As such, they are responsible for establishing and maintaining individual compliance regimes. In addition, they must meet all their other AML/ATF obligations, such as conducting client due diligence, client identification and record-keeping on behalf of the life insurance companies they are contracted with, and reporting suspicious transactions. Page 2 of 7

3 The requirement to establish a separate compliance regime is puzzling to many brokers. Firstly, because life insurance companies already have extensive AML/ATF compliance regimes and procedural oversight in place, as do many of the larger managing general agencies (MGAs) that brokers place their business through. The risk of life insurance products to be used for money laundering/terrorist financing is generally perceived to be lower than many other financial products because of the types of products sold, that life insurance companies and their broker/agents do not accept cash from clients and once a policy application is approved, the client becomes a policyholder of the company. Secondly, many life insurance brokers are also licensed to provide other financial services and products to clients. For example, they are often licensed as securities or mutual fund representatives. Yet under the PCMLTFA, for that portion of their financial business, they are not a reporting entity. The reporting entity in that situation is the securities or mutual fund dealer and, therefore, responsible for maintaining the compliance regime and training advisors. In practice, most of our members are small, independent operators of their own business, often working out of a home office, or sharing space with another broker. Indeed, some are older, semi-retired insurance brokers who only maintain their license in order to be able to service a small number of existing clients on a very occasional basis or simply to receive renewal commissions from past sales. There are thousands of independent life insurance brokers in Canada, yet every one of these brokers is required to have their own documented, 5-step compliance regime and be able to prove that is reviewed and updated at least every 2 years. They are subject to FinTrac compliance audits and fines for non-compliance. Indeed, in the fall of 2011, FinTrac began a random audit of 1,000 independent life insurance brokers across Canada testing whether they have a written compliance regime in place. We understand that this audit will continue through the spring What FinTrac will do with the results is unknown to us. However, we wonder at the utility of concentrating such resources on an industry whose products are recognized in Canada and internationally as being at low risk for money laundering activities. Even more troubling, however, is that FinTrac is expending resources on testing the compliance regimes of these individual brokers, many of whom (as explained above) are not big producers and whose activities pose little threat. Given this situation, and the changes being proposed to the Act, which will extend the oversight of life insurance companies to an even greater degree over its intermediaries, we question, and suggest it is time to review, the need for independent life insurance brokers to be reporting entities. The U.S. example - In the United States, insurance agents and brokers are not required to have a separate compliance regime because regulators judged it appropriate to site this responsibility with insurance companies for the following reasons: The insurance company develops and bears the risks of its products, and the responsibility for guarding against such products being used to launder illegally derived funds. Second, insurance companies, due to their much larger size relative to that of their numerous agents and brokers, Page 3 of 7

4 are in a much better position to shoulder the costs of compliance connected with the sale of their products. Finally, numerous insurers already have in place compliance programs and best practices guidelines for their agents and brokers to prevent and detect fraud. We believe that insurance companies largely will be able to integrate their obligation to report suspicious transactions into their existing compliance programs and best practices guidelines. 1 We suggest that the facts set out above are equivalent to the situation in Canada. FATF offers relief for low risk reporting entities: The amendments proposed in this consultation are intended to address potential compliance gaps raised by the FATF in its review of the Canadian model. However, the FATF itself provides for reasonable measures to reduce the compliance burden for small reporting entities where the country can be assured that the risk of money laundering is minimal, per the excerpt below: When a financial activity is carried out by a person or entity on an occasional or very limited basis (having regard to quantitative and absolute criteria) such that there is little risk of money laundering activity occurring, a country may decide that the application of anti-money laundering measures is not necessary, either fully or partially. In strictly limited and justified circumstances, and based on a proven low risk of money laundering, a country may decide not to apply some or all of the Forty Recommendations to some of the financial activities stated above. In light of the above, we urge the Government to give serious consideration to amending the Act such that independent insurance brokers would be removed from being a reporting entity under the Act and the requirement to establish an individual compliance regime. Establishing individual compliance regimes represents a huge compliance burden to brokers, yet does not contribute to the fight against money laundering or terrorist financing in any significant way. It is these brokers direct contact with customers during the sales process that makes them a valuable ally in this fight. This is the point where they are in a position to alert the company if the source of the investment assets, the nature of the client, or the objectives for which the insurance products are being purchased seem suspicious. This is where they have an important role in assisting the insurance company to prevent money laundering - not having thousands of individual brokers appointing themselves as their own compliance officer, producing written policies and procedures, conducting a risk assessment of their business, training themselves and reviewing their program every two years. As we noted in our December 2011 response to you, some jurisdictions (e.g. Australia, New Zealand) have sought out measures to reduce the compliance burden for low risk reporting entities. These measures have included establishing reasonable thresholds of materiality, where transactions or activity below a specified level are subject to reduced compliance requirements, or are exempt. 1 Source: US Department of Treasury, Financial Crimes Enforcement Network Guidance, FIN-2008-G004; Issued: March 20, 2008 Anti-Money Laundering Program and Suspicious Activity Reporting Requirements for Insurance Companies Page 4 of 7

5 In our view, this is a sensible approach and would provide some relief, especially for those of our members who are licensed intermediaries but conduct infrequent or small transactions, or deal with very low risk products. Such a threshold could be set based on annual financial activity (such as premium), or type of activity (products sold), so that those brokers who conduct little business, perhaps because they are semi-retired or sell mostly term insurance or whose primary business is employer sponsored group benefits plans, would not have to maintain an extensive compliance system. This is a far less preferable alternative to eliminating the compliance regime obligations for life insurance brokers, but would at least provide some relief for those brokers who are not particularly active in the marketplace. The following are our comments on some of the specific proposals under consideration. Proposal 1.2 The Government proposes to review the current exemptions from CDD and record-keeping for scenarios involving introduced business, in order to improve the continuity of record-keeping and to clarify how responsibility for the CDD information is divided among the party introducing the business and the party receiving the business. In addition, consideration will be given to expanding the scope of introduced business scenarios that would qualify for an exemption from certain CDD obligations. IFB Response: We understand that the FATF has recommended that reporting entities be required to take more responsibility for client identification and record-keeping requirements in introduced scenarios and has given Canada a non-compliant rating in this regard. For life insurance companies and brokers this means that the companies would no longer rely on brokers face to face contact with clients to satisfy the CDD on behalf of the insurer and the insurer would keep copies of the identification data for itself. If the current reliance by life insurers on brokers to is to be removed, then this is a further indication of the companies responsibilities which need not be duplicated by their brokers. Proposal 2.4 The Government is giving consideration to amending the PCMLTFR to expand the client identification and record-keeping requirements applicable to life insurance companies and life insurance brokers and agents beyond the specified purchase of annuities and life insurance policies. Client identification and record-keeping requirements would apply to transactions and accounts openings for investment and loan products offered by life insurance companies, agents and brokers that are not currently captured under the PCMLTFR. The requirements would be comparable to those currently imposed by the PCMLTFA on other financial entities and securities dealers. Page 5 of 7

6 Eliminating the exemption for income tax purposes and the $10,000 threshold for the cost of an annuity or policy would result in the requirements applying to more annuities and life insurance policies that may provide opportunities for money laundering. IFB response: The proposed amendments would eliminate the blanket client identification and record-keeping exceptions that currently exist for specified low risk financial products/transactions. These include registered plans (RRSP, RRIF), employer sponsored group plans and annuities. This change will lead to a much greater compliance burden and potential for FinTrac to find deficiencies if life insurance brokers are required to conduct CDD and recordkeeping related to products which are recognized as being at minimal risk of being used for money laundering/terrorist financing. We would urge the Government not to proceed with this proposed amendment. Proposal 6.1- Broadening the Requirement to Report Suspicious Transactions Reference: PCMLTFA, section 7 The Government is giving consideration to broadening the requirement to report suspicious transactions to encompass activities conducted for the purpose of a financial transaction. This would clarify that reporting entities would be required to submit a suspicious transaction report if, for example, an account application were considered suspicious. IFB Response: We are concerned about the practical application of this requirement, since life insurance brokers often will not collect detailed client information when meeting with a new client until some mutual agreement is reached to provide a service. Trying to collect such information for transactions that are attempted or not completed, for example, after the client decided not to proceed with the transaction or application, would place the advisor in a difficult situation and may lead to tipping off the client, contrary to Section 8 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Conclusion To summarize, we would argue that since the insurance companies and securities dealers independent brokers are contracted with are subject to the Proceeds of Crime (Money Laundering) Terrorist Financing Act they require their brokers who deal with clients to be knowledgeable and compliant with the client identification, record-keeping and suspicious transaction reporting requirements under this Act. This is appropriate given their shared business relationship and is a prerequisite to the mutual fund company or insurance company accepting new business. Furthermore, it recognizes the gate keeper role of the broker, as generally the first point of contact with the consumer. The gate keeper function is a suitable and important role but in our view does not, of necessity, need to make the broker a reporting entity. We believe that this review of the PCMLTFA presents an excellent opportunity to rethink some of its original premises and develop a more workable but equally effective framework. Page 6 of 7

7 IFB appreciates the opportunity to contribute to this consultation. questions, please contact the undersigned. Should you have any Yours truly, John Whaley Executive Director Page 7 of 7

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