Record keeping requirements under the PCMLTFA and associated regulations
As of June 1st, 2021, anytime Sun Life is required to remit funds of $10,000 or more to a beneficiary over the duration of a non-tax exempt insurance policy or non-registered annuity, you are required to record and complete the following on the beneficiary:
- Create an information record
- Verify the identity (VOI)
- Determination of Politically exposed person/head of international organization (PEP/HIO) and source of wealth (SOW) (if applicable)
The above requirements apply to the following products:
- All non-tax exempt permanent life insurance
- All non-tax exempt universal life
- All non-registered individual variable annuity contracts (segregated funds)
- All non-registered annuities (e.g. accumulation, payout)
FINTRAC defines a beneficiary as: the individual or entity that will benefit from a transaction or to which the final remittance is made.
A beneficiary can be:
- an individual or entity beneficiary receiving money from a death claim
- a non-owner payee receiving funds
- an owner of a policy/account receiving money from their own policy (i.e. withdrawal, loan, cash surrender).
Important information on non-tax exempt insurance policies
- Most of Sun Life’s insurance policies are exempt policies as defined in subsection 306 (1) of the Income Tax Regulations. Therefore, they are exempt under the Proceeds of Crime and Money Laundering Act and associated regulations.
- Submit the claim and Sun Life will let you know if we need verification of identity for the beneficiary.