What if I can't meet a Client face-to-face to verify their identity?
You can verify the Client’s identity via video conference using the Dual Process method. The Client may also meet with a 'qualified professional' (also referred to as an Agent or Mandatary) to complete the Non face-to-face identity verification by agent or mandatary, third party determination and politically exposed persons (PEP) (4355-E) if you are not able to verify identity via video conference.
Please call us at 1-800-800-4786 to discuss options.
Can I use the government-issued photo identification method if a person is not physically present?
No. Currently, Sun Life does not have the technology to authenticate government-issued photo identification documents for this method.
Note: It is not enough to only view a person and their government-issued photo identification document through a video conference or another type of virtual application.
I work with various licensed advisors and we sometimes will conduct transactions on behalf of one another. If I am conducting a transaction with another advisor's client, do I have to verify the identity of that client when their advisor of record has already established identity?
Yes, an advisor conducting a new transaction with a Client (whether their own Client or another advisor's Client) must verify the identity of that Client. If ownership of a contract changes on a policy/account, you must verify identity of the new owner. Lastly, you must collect verification of identity on Clients you don't recognize and/or have doubts about the original information collected by the other advisor.This may include Clients you are servicing on behalf of another advisor or Clients transferred to you from inventory.
Am I required to collect AML/ATF information on all new transactions?
- Yes, a licensed advisor is required to collect AML/ATF information (including identity verification) on every new sale of:
- universal life insurance
- permanent life insurance
- non-registered guaranteed investment certificates (GICs)
- non-registered accumulation annuities
- non-registered payout annuities
- all non-registered individual variable annuity contracts (segregated funds)
- non-registered mutual funds.
If I collected AML/ATF information on a new client and they want to make a subsequent unscheduled deposit to their universal life or permanent life policy or non-registered wealth product, do I need to ask AML/ATF information again?
No, an advisor does not need to verify the identification of an existing client on subsequent transactions to an existing policy or account.
I hire staff to assist me in my business. Can my staff collect the AML/ATF information on the client?
Only licensed life insurance advisors contracted with Sun Life may verify client identity.
How do I set up my own compliance regime and appoint a compliance officer?
Refer to the Implementation of a Compliance Regime on the FINTRAC website. You can formally adopt the manual, appoint yourself as the compliance officer and set up procedures based on the guidelines in the manual.
What if clients refuse to answer the Politically exposed persons (PEP) / Head of an international organization (HIO) questions?
While you cannot control the information that your client is willing to provide, the legislation does require you to obtain an answer from your client, in order to satisfy your statutory obligation.
Is asking my client if they are a PEP/HIO violating privacy legislation in Canada?
We are collecting this information to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act for risk management purposes.
How long do I have to submit outstanding AML/ATF documentation?
AML/ATF documentation timelines will be indicated in any communication you receive requesting the outstanding information.
What if my client refuses to complete the AML/ATF section?
You may not do business with this client and should report the incident as a possible attempted suspicious transaction to the email address Money Laundering. Sun Life will investigate and may report this to FINTRAC.
Where can I get help to correctly complete form 4830-E or 4831-E?
What should I do if I suspect my client has a third party involved in the contract/application but answered "No" to the third party determination question?
If you suspect that a third party may be involved in the transaction, but your customer has answered 'no' to the third party determination question, send an email to Money Laundering and include the following details:
- your full name and advisor number
- your business address and telephone number
- the name and address of the individual suspect to have third party involvement in the policy/contract
- the policy or account number
- the reasonable grounds you have to suspect a third party has involvement in the policy/contract