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

Each person opening any form of deposit account at a financial institution is subject to the same set of federal or provincial Anti-Money Laundering Procedures, due diligence and regulations.

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 and CDIC to ensure the FIs are in compliance with the Act.

Fiscal Agents Savings and Investments (FASI) acknowledges the importance of identifying clients for the purpose of opening new accounts and determining if a transaction is suspicious where money laundering is concerned. FASI also understands that as a broker for various FIs, we must assist the FIs in their reporting and anti-money laundering (“AML”) responsibilities.

To assist with the AML effort and reporting requirements of the FIs, FASI has laid out the following New Account Opening and Anti-Money Laundering Procedures and Due Diligence, which we require all representatives, employees and RDBA member broker/agents associated with FASI (the Broker) to follow at the very minimum. When placing a transaction with a particular Fl, the AML requirements laid out for the corresponding Fl must also be recognized and the representative must act in accordance with these requirements.

The procedures below were developed to coincide with current FI AML requirements and current industry standards, such as the RDBA AML standard.
As all accounts and transactions are different, each particular account and transaction should be reviewed by a compliance officer at the respective FI for whom the deposit account will be opened. Each FI’s written policies and procedures override the following, and as always, the FI reserves the right to reject and return any deposit or new account that they find non-compliant.

Government Information Required

Source of Funds

Acceptable: Client’s Personal Cheque made payable to the Fl (or coincide with the names) 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).
1. or Maturity Cheques) issued by a CDN Financial Institution; made payable to the
2. Applicants in the same registration as the new GIC

Not Acceptable: Cash, counter cheques, money orders, drafts, travelers cheques or other axe permitted to be accepted in any value – no exceptions!

Know Your Client (KYC)

FASI requires that all clients meet in person where possible with the FASI Broker prior to any GIC being purchased.

FASI 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.

Non-Face to Face

All clients for whom a personal contact is not possible, the Identity Verification Record (IVR) document is to be used. Each person to be registered on the investment must have the IVR completed by their bank.

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 Names
Civic Address of all registered owners
Phone Number
Occupation (if `self employed’ state nature of business, if`retired’ state previous occupation)
Employers name, address and phone number
Relationship of each joint owner to one another
Date of Birth
Social Insurance Number (SIN)
Third Party Declaration (for each individual transaction)
Politically Exposed Foreign Person Determination
Signature of all registrants
Two pieces of Canadian Government issued identification, valid (unexpired)
Intended use of the account
Completed and Client Signed RDBA Client Information and Consent Form (CICF)
Copy of the cheques) 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
Name(s). SIN, DOB, Address, Occupation, 2 Pieces of ID*, valid (unexpired), of the Executors) / Trustee(s)
Third Party Declaration (for each transaction)
Politically Exposed Foreign Person Determination Signature of all Executors)/Trustee(s)
Intended use of the account
Completed and Client Signed RDBA Client Information and Consent Foam (CICF)
Copy of the cheques) used to purchase the investment

Informal Trusts

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
Two pieces of ID* for the authorized persons) 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

Nominee Accounts In-Trust

Full Name of the nominee and beneficial owners)
Date of Birth of the beneficial owners)
Current Address of the beneficial owners)
Country of Residence of the beneficial owners)
Social Insurance Number (or equivalent if foreign resident) for the beneficial owners)
The FI will verify if the nominee name is in fact froman 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
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).

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.

Note: Some Fls may require a photocopy of the front and back of identification; many FI’s do not accept applications for minors.

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 **
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)

Also including health cards issued by:

British Columbia (signature only)
Alberta (no picture of signature)
Saskatchewan (no picture or signature)
Quebec (may be used only if clients offers it as ID – broker must NOT ask to see a Quebec Health Card)
Nova Scotia (signature only)
Newfoundland & Labrador (no picture or signature)

If a foreign resident: Passport is mandatory.
**One piece must be identification that contains both a picture and a signature. The second piece may be any other in the list above.