You’re required to determine if there’s a third party involved when establishing a new account/policy or receiving funds at any time for:
- non-registered wealth products,
- universal life and
- permanent life products.
A third party could include:
- A payor who is different from the account/policy's owner (e.g. a relative, spouse/partner),
- A legal entity, (a corporation, partnership, association, etc.) that is not owner of the policy/contract,
- An individual appointed by the Client to act on their behalf (e.g. a Power of Attorney),
- Someone not formally associated with the accounts/policies, but likely to benefit from them, or
- A collateral assignee/hypothecary creditor.
When a third party is involved in an application, their name won't appear as the applicant.
The Client's response to the third party determination question must be recorded.
If the Client answers 'no':
- Indicate "no" in the third party determination section of the application.
If you’re not able to make a third party determination but have reasonable grounds to suspect that a third party is involved, and the Client 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
If the Client answers 'yes':
- Indicate "yes" in the third party determination section of the application.
- Record the third party's information in the third party determination section of the application. If the application does not include this section, complete:
