New Account Opening and Anti-Money Laundering Procedures and Due Diligence

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1 New Account Opening and Anti-Money Laundering Procedures and Due Diligence Last Revised: January 1, 2013 Canadian Financial Institutions ( FIs ) are regulated by the Office of the Superintendent of Financial Institutions ( OSFI ). Under the terms of OSFI s guideline B-8, Deterring and Detecting Money Laundering and Terrorist Financing Activities, the FIs are required to perform certain tasks to assist in both the prevention of money laundering and the investment of proceeds of criminal activities, in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act ). The Act established the Financial Transactions and Reports Analysis Centre of Canada ( FINTRAC ) as the agency responsible for the collection, analysis and disclosure of information provided by reporting entities to assist in the detection, prevention and deterrence of money laundering and terrorist financing in Canada and abroad. FINTRAC works closely with OSFI to ensure the FIs are in compliance with the Act. Deposit Broker Services Inc ( DBS ) acknowledges the importance of identifying Clients for the purpose of new account opening and determining if a transaction is suspicious where money-laundering is concerned. DBS also understand that as a broker for various Financial Institutions, we must assist the Financial Institutions in their reporting and anti-money laundering ( AML ) responsibilities. To assist with the AML effort and reporting requirements of the FI s, DBS has laid out the following New Account Opening and Anti-Money Laundering Procedures and Due Diligence, which we require all contracted Brokers, along with their representatives, employees, and suboffices (the Broker ), to follow at the very minimum. When placing a transaction with a particular FI, the AML requirements laid out for the corresponding FI must also be recognized and the representative must act in accordance with these requirements. The below procedures were developed to coincide with current FI AML requirements and current industry standards, such as the Registered Deposit Brokers Association ( RDBA, formerly the FCIDB) AML Standard. As all accounts and transactions are different, each particular account and transaction should be reviewed by a compliance officer at the respective Financial Institution for whom the deposit account will be opened by. Each FI s written policies and procedures override the following, and as always, the FI reserves the right to request additional compliance information and has the right to reject and return any deposit or new account which they find non-compliant. Brokers are required to have an acceptable privacy policy in place in order to protect private client information. All employees should be trained on the Broker s privacy

2 policy. Privacy, security and intrusion prevention must be a consideration when selecting an operating location which includes storage of client files and transaction documents. Client documents and sensitive information should be stored and secured in locked cabinets. A clear desk policy should also be established. Any original transaction documents which are not being forwarded to DBS or the Issuer must be securely kept for 5 years past maturity of the deposit instrument, or as required by applicable regulations and privacy rules. Disposal of sensitive documents must be properly handled to ensure privacy is maintained. Effective February 1 st, 2013: Deposit Broker Services Inc. requires that every application, placed under DBS broker number, be signed by a representative who is a member in good standing with the RDBA and by a member who has successfully completed their annual RDBA sanctioned AML training

3 Source of Funds Acceptable: Client s Personal Cheque made payable to the FI (or coincide with the name(s) of the registration) and drawn from accounts with a Canadian deposit-taking institution. The name on the cheque must match the name of the applicant(s). The personal cheque should be pre-encoded with the account holders name and address at the top left hand corner. or Maturity Cheque(s) issued by a CDN Financial Institution; made payable to the Applicants in the same registration as the new GIC Not Acceptable: Cash, counter cheques, money orders, drafts, travelers cheques or other are NOT permitted to be accepted in any value no exceptions! Brokers are NOT permitted to use their trust account. If a maturity cheque needs splitting, the client should do so by depositing the maturity cheque into their personal account and subsequently write a personal cheque back out for the correct amount to the corresponding issuing company (ensure a hold is not placed on the funds to avoid NSF on deposit) Know Your Client (KYC) DBS requires that all clients meet in person with the Broker prior to any GIC being purchased. DBS also requires that a Third Party Determination be made, in order to identify if someone other than the client or its authorized representative is instructing the client or its authorized representative in the transaction. The Broker must obtain and record the following details for each client, registration, and/or transaction, along with the issuing FIs AML and KYC requirements: Individuals (with or without Joint Tenants) Full Name(s) Civic Address of all registered owners Phone Number Citizenship, Residency, US Persons status Occupation (if self employed state nature of business, if retired state previous occupation, if manager or consultant state additional details; be as detailed as possible ex: the industry) Employers name, address (some Financial Institutions require the employers phone number) Relationship of each joint owner to one another Date of Birth Social Insurance Number (SIN) Third Party Declaration (for each transaction) Politically Exposed Foreign Person Determination (Politically Exposed Person Determination may be required by some Issuers i.e. domestic)

4 Signature of all registrants Two pieces of Canadian Government issued identification*, valid (unexpired) (accepted list varies from Issuer to Issuer) Intended use of the account Completed and Client Signed RDBA Client Information and Consent Form (CICF) original must be kept in the client s file at the Broker s office Copy of the cheque(s) used to purchase the investment Estates / Formal Trusts Name of the Estate / Deceased Registration Number with CCRA (Trust Number) Copy of the Last Will and Testament with Letters of Probate Copy of Death Certificate Executor(s) / Trustee(s): Name, SIN, DOB, Address, Occupation, 2 Pieces of ID* valid and unexpired Third Party Declaration (for each transaction) Politically Exposed Foreign Person Determination Signature of all Executor(s)/Trustee(s) Intended use of the account Completed and Client Signed RDBA Client Information and Consent Form (CICF) based on the Executor(s) / Trustee(s) Copy of the cheque(s) used to purchase the investment InFormal Trust Same requirements as Individual(s) Obtain relationship of in trust for individuals to the registered owners Corporate and Other Business and Non-Profit Entities Full Name of the Entity Current operating address and phone number Nature of the business/organization Registration Number used to identify the business with CCRA (BIN/BN) Articles of Incorporation, By-Laws A list of persons authorized by the organization to bind the organization An incumbency certificate showing persons authorized to bind the entity Listing of Corporate directors, owners or partners including their address and occupation Record the details of two (2) pieces of ID* for the authorized person(s) making the application Any other Documents used to identify the business Documents showing the authorized individuals with signing authority Politically Exposed Foreign Person Determination Beneficial ownership to be reported for each individual who directly or indirectly owns or controls at least 25% Indicate if the organization is a registered charity, and if not, whether or not the organization solicits donations from the public Intended use of the account

5 Some Issuers may request: Notice of Assessment from CRA, dated within the past 18 months, as proof of current status/existence of entity, as well as other proof of existence Nominee Accounts In Trust Full Name of the nominee and beneficial owner(s) Date of Birth of the beneficial owner(s) Current Address of the beneficial owner(s) Country of Residence of the beneficial owner(s) Social Insurance Number (or equivalent if foreign resident) for the beneficial owner(s) The FI will verify if the nominee name is in fact from an MFDA or IDA member. Nominee names that are not from MFDA or IDA members are not acceptable. Applications Signed by a Power of Attorney Certified true copy of the POA document (Individual FIs may require a notarized copy or may not accept such accounts utilizing a POA) Application / Membership Application based on the Applicant (applicant must satisfy the requirements for an individual) but signed by the POA. Name, civic address, DOB, occupation and 2 pieces of ID* are required for the POA ** (POA must satisfy the requirements for an individual and broker must complete an RDBA CICF based on the POA and signed by the POA). Also refer to requirements under Individual(s) Minors Where a deposit is made by anyone under the legal age of majority, the identity of the person s father, mother or guardian must be ascertained. The minor must also be able to sign the application/consent form. Minors must provide acceptable identification and meet the requirements of an individual. Note: Some FIs have minimum age restrictions and may not accept applications from minors. * NOTE: DBS advises against sending physical copies of identification unless a specific request is made directly from the FI;

6 Accepted Identification To qualify as identification, an original, valid (unexpired) document in good condition, issued by a Canadian Government body (Federal, Provincial or Territorial), must be viewed and a record maintained of the; (A) Type of ID, (B) Reference Number, (C) Place of issue and (D) Expiry Date INCLUDING BUT NOT LIMITED TO: Drivers License ** Current Canadian Passport ** Certificate of Canadian Citizenship ** Provincial Issued Photo ID Card *** NEXUS Identification Card *** Firearms Licence *** Certificate of Naturalization Permanent Resident Card Birth Certificate Issued in Canada Old Age Security Card issued by the Government of Canada **** Certificate of Indian Status issued by the Government of Canada Social Insurance Number card (must be physically viewed by the broker) **** Health cards issued by: o British Columbia (signature only) o Alberta (no picture of signature) o Saskatchewan (no picture or signature) o Quebec (may be used only if clients offers it as ID broker must NOT ask to see a Quebec Health Card) o Nova Scotia (signature only) o Newfoundland & Labrador (no picture or signature) If a foreign resident: passport is mandatory (non-resident accounts may not be accepted check with the Financial Institution before placing a deposit) **One piece must be identification that contains both a picture and a signature. The second piece may be any other in the list above. ***Not all Issuing Companies have revised their AML policies to include acceptance of this form of identification use with the Financial Institution s prior approval ****Not an acceptable form of ID with all Financial Institutions The Financial Institution s AML and KYC requirements may be found on gicinvest.net or obtained by phoning the respective FI and must be reviewed prior to and honored during any transaction or new account opening.

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