🎰 Standing Senate Committee on Banking, Trade and Commerce

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Cayman Islands' financial system against money laundering, terrorist gambling activities i.e.: use of casinos, internet gambling 12 Money Laundering and Terrorist Financing (ML/TF) Typologies and Trends for Canadian Money Services​.


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Measures to prevent and mitigate money laundering and terrorist financing must be particularly FINTRAC, about the trends out there that we should be aware of​. However, surely more typologies that define behaviour could be provided to us so I would like to describe the Canadian casino gaming industry from a high​.


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Canadian standards set by the PCMLTFA protect against money laundering and term trends, so that reporting entities can properly assist FINTRAC. casino operators, employees, and frontline gaming personnel are trained in anti- During the Committee's travels, witnesses noted that criminal typologies are changing.


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Overall, there is significant global casino activity that is cash intensive, in their Money Laundering Typologies and Trends in Canadian Casinos Report.


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global fight against money laundering and terrorist financing. financing typologies and trends in Canadian PCMLTFA, including the casino disbursement.


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List of indicators of money laundering and terrorist activity financing for casinos. to transactions that involve non-Canadian jurisdictions; ML/TF indicators related to environment, high risk jurisdictions and trends are often subject to change.


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trends of money laundering, with a short note on terrorist financing, and address A. Traditional Money Laundering Typologies. 1. pawn broker, all types of money service businesses, casinos, dealers in real estate, and dealers in precious The defendant had bank accounts in Canada, Spain, England, Pakistan, Japan.


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Title, Money Laundering Typologies and Trends in Canadian Casinos. Contributor, Centre d'analyse des opérations et déclarations financières du Canada.


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Overall, there is significant global casino activity that is cash intensive, in their Money Laundering Typologies and Trends in Canadian Casinos Report.


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Casinos in Canada are subject to reporting and anti-money laundering (AML) terrorist financing risks and of the most frequent money laundering typologies in “Money Laundering Typologies and Trends in Canadian Casinos”, November,​.


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We have one hour for this meeting. For the purpose of today's discussion, I will refer to MGAs, distribution offices and intermediaries as interchangeable, because we get called different things, and likewise the discussion about agent, broker and market intermediary and advisor should mean the same thing. We also function as sales and support to the adviser in giving them information about the product and what have you to help them market that product. The adviser holds the appropriate licences, governed by the provinces that they are representing, and they also have contracts with the insurance companies that they represent. With respect to policies that have an investment component, where there is a cancellation option, absolutely, there is a possibility for activity to take place.{/INSERTKEYS}{/PARAGRAPH} Money orders or even bank drafts are very limited. CAILBA membership is a little concerned, though, about the manner in which the regulation currently exists. In point 3, you make the statement: "In our opinion, most life insurance contracts are not viable for money laundering. The industry believes that it is of crucial importance to update this legislation on a regular basis, particularly in light of the new and revised international standards that were adopted by the Financial Action Task Force — the FATF — last month. What is good, though, is that we have been working with the Canadian Council of Insurance Regulators, and that is the body that represents each provincial licensing area, and it is called CCIR. I refer in point 2 to where you state: "In the course of processing business for the adviser and the insurance, we do not accept cash regardless of the size of the transaction. There are such offices in Canada, and they range from a a nation-wide organization to a small local shop or operation. In our opinion, life insurance is not a viable money laundering product. We would be pleased to respond to any questions. They talked about how the purchase of a life insurance policy with a large down- payment and the subsequent cancellation of the policy and return of the down-payment is one type of money laundering scheme seen in the life insurance industry. Hopefully Canada will do the same. Swedlove indicated, we, too, do not accept any cash, no matter the amount. We just hope that the current disconnect between how we are regulated and the actual function that we perform is not magnified again by some further changes and whatever is adopted takes into account the low risk nature of our business, what we do, our need for far more specific information about how money is really laundered and looking at it in a cost-effective way. In conclusion, Mr. The way the regulation is set up right now, we are actually considered advisers, assuming that we have end customers, rather than just service providers. My real job is to head up one of such managing general agents. This approach is meant to ensure efficient allocation of resources and minimize the compliance burden. It is the adviser who performs all of the mandated functions they have to do. As Mr. It is always a pleasure to appear before this committee. The majority of the life insurance processed in Canada by the MGA channel is processed by members of our association. I could talk more about that later. It is the adviser who is in the position to determine whether or not the circumstances or the reasonableness of this transaction makes a lot of sense because they are meeting with the client face-to-face. We are suggesting that there are certain products that do not lend themselves to money laundering activity. We like to call ourselves MGAs. Indications are that many countries will allow their financial institutions to apply, subject to national legislation, simplified measures when assessing risks under the internationally agreed risk-based approach. The first statement says:. It is the adviser who verifies and ascertains identification. Whereas a long-standing customer buying a life annuity through a captive life insurance agent would be considered in our view lower risk, a new customer purchasing the same product via telemarketing may represent a higher risk situation. Moreover, the October risk-based approach guidance of the FATF for the life insurance sector will soon be updated in cooperation with the industry to identify characteristics of: i customer risk; ii product, service, transaction or delivery channel risk; and iii country risk, indicating that simplified mitigation strategies may be warranted. The examples I gave in my presentation were critical illness insurance, for example, term insurance. We have put in place compliance regimes. Unlike banks, insurers do not accept cash and are therefore not involved in what we call the placement stage of money laundering. We know we have a part to play, and we are willing to play a part. I will give you some examples. These products include individual and group life insurance, individual and group annuities, including RRSPs, RRIFs and pensions, and supplementary health insurance. We are the back office support between the adviser and the insurance company, making sure that the transaction or the insurance application gets moved from the adviser through to the insurance company. Today's subject is an area of particular interest to me over many years and we in the industry have a significant interest in this matter. We believe that the rest of the provinces will follow something close to that. Companies could have the flexibility to verify the identity of customers after the establishment of the business relationship, or companies could reduce the degree of ongoing monitoring and scrutinizing of transactions, or companies could be relieved from seeking more information on the purpose and intended nature of the business relationship. In this simple example, an application of the risk-based approach by means of permitted, simplified measures in regard to the lower risk transaction would minimize the compliance burden of the insurer supplying this annuity product. However, the insurers do expect us to follow guidelines that are in place. We also are responsible for the compliance side, the market conduct compliance support for the insurer. There are a number of ways of simplifying the rules for checking for money laundering activities where the risk is lessened. With respect to other products, a risk-based approach should be applied. Swedlove, we will hear from you first, followed by Mr. We believe this industry is a very low risk industry. Insurance though, overall, is clearly less risky than banking. In such circumstances, and provided there has been an adequate analysis of the risk by the financial institution, it would be reasonable for Canada to allow its financial institutions to apply simplified consumer due diligence measures. The Chair: I would like to start by referring to something you said in your opening comments in points 2 and 3. We think that the stakeholders on our side of the world, in the insurance world, can find some cost-effective ways that we can mitigate some of this risk, and I would be happy to share with you my comments on that. Measures to prevent and mitigate money laundering and terrorist financing must be commensurate with the risks identified. We have trained our staff for anti-money laundering and all of that. The function of an MGA is threefold. They will be followed by a panel from the gaming industry during the second half of our meeting. {PARAGRAPH}{INSERTKEYS}This is our eleventh meeting on the subject. That is, in summary, what they had to say. To continue on, insurers do not delegate the anti-money laundering responsibilities to us. There has to be a bunch of hoops to go through before we will accept even a bank draft. They are engaged in a review. It is the adviser that meets with the client. This industry is great for acronyms, so apologies beforehand. We have not met the client, and we do not know what the discussions were in the course of the transaction. Those are basically our three roles. The current regulation imposes some extremely difficult and expensive requirements on MGAs, again because of this issue of us being considered the selling adviser. They are up to speed on reporting and submitting of reports. This is a new recommendation fully supported by the international insurance community, and the financial services sector more broadly. We have put in place policies and procedures. Within insurance, some products are simply not suited as a vehicle for money laundering, such as term life insurance and critical illness insurance. I am sorry for the confusion, but I like the softer word "adviser," so I will use that probably throughout the rest of my comments. In this first half of today's meeting we are pleased to welcome a panel representing the insurance industry. What is of particular interest to us, though, is that B. I welcome the opportunity to have some more dialogue, and thank you again for the opportunity to be here today. Chair, we welcome this opportunity to appear before the committee as you review the Proceeds of Crime Money Laundering and Terrorist Financing Act. My comments today will relate to the risk-based approach that is necessary for a cost-effective regime. On the international front, the FATF has made the risk-based approach its recommendation 1. Over the last month, the committee has focused its efforts on hearing from a number of so-called regime partners involved in the implementation and administration of this legislation. To create regulation that would indicate that and make us follow that compliance could really put us offside, because it is impossible for us to know. The Government also recognizes the need to minimize the compliance burden on the private sector. I would like to open my remarks by noting the Canadian life and health insurance industry's appreciation for the following two statements contained in Finance Canada's consultation paper. Managing general agents are the largest distribution channel of life and health insurance policies in Canada. As was indicated, my name is Allan Bulloch, and I am the legislative director of CAILBA, which is a voluntary trade organization whose interests are the managing general agents in Canada. We are considered a reporting entity, just like the other , entities that apparently exist. This new regulation is really ratcheting that up further, which causes us even more concern. What will be interesting, though, is that MGAs started to exist in the early s, perhaps, and the Bank Acts were set up prior to that. We are pretty sure what the review will say. Having heard the internal perspective, we now continue our efforts to hear an external perspective. I take those two statements and refer to some testimony we heard yesterday from Capra International, who, as you know, performed the year review. It should come out in the next couple of months. Over the next few weeks we will continue to hear from those familiar with and impacted by the regime, including industry groups and associations, as well as independent experts in the field. Of particular concern is the effort in the November consultation paper that establishes that there is a business relationship between the customer and us, when no such relationship exists. For products such as these, one really questions the need for any AML review. The general principle of the risk-based approach is that where there are higher risks countries require financial institutions to take enhanced customer due diligence measures, such as dealing with politically exposed foreign persons, and that, correspondingly, where the risks are lower, simplified measures may be permitted. It is great to be able to participate in this parliamentary review of the Proceeds of Crime Money Laundering and Terrorist Financing Act.