On June 1, 2021, amendments to the Federal AML legislation and FINTRAC guidance will come into force. Changes include new requirements pertaining to beneficiaries, clients who are entities, politically exposed persons (PEP) or Heads of International Organizations (HIOs), beneficial ownership, and third-party determination. Please become familiar with the changes and consult your own AML policy and procedures or those made available to you through your MGA.
ivari changes to processes and forms
As a result of the regulatory changes, ivari has updated its relative processes and forms.
As of June 1, ivari will be collecting information from beneficiaries to create information records, verify their identity, and determine if they are politically exposed. As well, ivari will be monitoring client and claimant records to ensure information records and verifications are current.
Advisors will be required to collect and maintain specific beneficiary information for Universal Life policies and non-registered annuity contracts (including segregated fund, GIA and SPIA contracts) at time of a claim to prevent money-laundering, including:
Beneficiary’s name, address, date of birth, telephone, occupation, and relationship to the insured
Beneficiary’s identification required; the claim forms are updated to capture a government issued photo ID information
Any beneficiary who will be receiving a death benefit of $100,000 or more will need to complete the following form:
The new “Politically Exposed Persons and Head of International Organization for Claims (CL2110) form
A new question “What is the source of your accumulated assets?” was added to the above form to establish the source of the person’s assets if the person or entity is deemed a PEP or HIO
Please use the following revised or new forms/applications for your client interactions:
CriticalADVANTAGE Claimant’s Statement
Insured’s Statement for Disability and Waiver Claim
Critical Illness Claimant’s Statement
Insured's Request for Living Benefits
Politically Exposed Persons and Head of International Organization for Claims- NEW
Insured's Request for Compassionate Assistance Benefit
Claimant’s Statement (Life Insurance Claim)
Claimant’s Statement (for Investment Products)
Dealer/Nominee Transfer Form
Transfer of Ownership – Investment products
Politically Exposed Persons and Head of International Organization
Corporate/Non-Corporate Entity/Trust Ownership
Policy Ownership for Corporate & Non-Corporate Entities or Trusts
Identity and Third Party Determination
Single Premium Immediate Annuity (SPIA) Application
Notice of Transfer of Ownership for Insurance Products
Pre-Authorized Debit (PAD) for Insurance Products
To help you better understand these changes and how they impact your business, we have created an FAQ document.
ivari makes no warranty or representation to you that compliance with this communication will be adequate or satisfactory for you to be in full compliance with the above mentioned legislative and FINTRAC guidance amendments and/or your own purposes.