Anti-Money Laundering Policy and Anti-Terrorist Financing Policy

The purpose of Introduction Capital Inc. (IC) Anti-Money Laundering and Anti-Terrorist Financing Policy (AML Policy) is to demonstrate IC’s commitment to prevent, detect and address non-compliance in regards to money laundering and terrorist financing activities. IC will not knowingly participate in any capacity in the advancement of a transaction that is suspected to be related to the commission of a money laundering or terrorist financing activity.

IC will comply with record-keeping, client identification, reporting and compliance requirements of the federal Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA); Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations; the Canadian Criminal Code; and the United Nations Suppression of Terrorism Regulations.

PCMLTFA creates a mandatory reporting system for suspicious and prescribed transactions and the cross-border movement of large amounts of currency and monetary instruments.

Canada is also a member of Financial Action Task Force (FATF), the agency that establishes international anti-money laundering standards. Canada has also signed and ratified the United Nations International Convention for the Suppression of the Financing of Terrorism and the Anti-Terrorism Act (ATA). The ATA creates measures to deter, disable, identify, prosecute, convict and punish terrorist organizations. In addition, the ATA provides new investigative tools for law enforcement and national security agencies. Specifically, the ATA make it a crime to: knowingly collecting or providing funds, either directly or indirectly, used to carry out terrorist activities; knowingly participating in, contributing to or facilitating the activities of a terrorist organization; instructing anyone to carry out a terrorist activity on behalf of a terrorist organization; or knowingly harbouring or concealing a terrorist.

The Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism and the United Nations Al-Qaida and Taliban Regulations (UN Regulations) provide a list of individuals or entities believed to be involved in, or associated with, terrorist activity (UN List). The UN Regulations, through resulting amendments to the Criminal Code, make it an offence for anyone in Canada, or any Canadian outside of Canada, to collect funds from, or provide funds to, any individual or entity appearing on the UN List.

FINTRAC is an anti-money laundering agency established by PCMLTFA.

FINTRAC’s mandate is to collect, analyze, assess and, where appropriate, disclose information relevant to the investigation and prosecution of money laundering and terrorist financing offences. FINTRAC is also responsible for conducting research and for undertaking educational measures to inform the public, those who are required to report suspicious transactions and the law enforcement community about the nature and extent of money laundering and terrorist financing activities, and effective detection, prevention and deterrence measures.

The United Nations (UN) defines money laundering as “any act or attempted act to disguise the source of money or assets derived from criminal activity.” It is the process whereby “dirty money” (money generated through criminal activity) is transformed into “clean money,” the criminal origin of which is difficult to trace. Money laundering has three recognized stages:

  1. Placement – placing the proceeds of crime into the financial system. Also referred to as the “physical disposal” of cash proceeds derived from illegal activity. 
  2. Layering – separating illicit proceeds from their source by creating complex layers of financial transactions designed to disguise the audit trail and the source and ownership of funds (i.e. through the use of monetary instruments and electronic funds transfers). 
  3. Integration – adding an apparent legitimacy to criminally derived wealth. For instance, via a complicated web of transactions designed to make tracing of the original source nearly impossible. Upon success of stage two of layering, integration then places the laundered funds back into the economy so they look as if they are normally derived proceeds of business. 

Any of the three stages may occur consecutively or concurrently.

In Canada, a money laundering offence involves concealing or converting property or the proceeds of property, knowing or believing that the property or proceeds were derived from the commission of another offence (predicate offence). Predicate offenses include, but are not limited to: drug dealing, bribery, gaming, robbery, fraud, theft, extortion and counterfeiting.

Methods of money laundering include:

  1. Smurfing – smurfs depositing cash or buying bank drafts at various institutions, or one individual executing a series of consecutive transactions in dollar amounts slightly less than the amount that triggers the requirement to report the transaction to FINTRAC, and the cash is subsequently transferred to a central account.
  2. Nominees – recruiting family members, friends or associates who are trusted members of their community in order to conceal the source and ownership of the dirty money being laundered.
  3. Bulk Cash Purchases – when individuals purchase large value items such as cars, boats and real estate using cash that are often registered in a friend or relative’s name.

FINTRAC describes terrorist financing as the provision of monies for terrorist activity including funds raised from legitimate sources, such as personal donations and profits from businesses and charitable organizations, as well as from criminal sources, such as from predicate offences.

Similar to money laundering, terrorist financing activity is intended evade authorities’ attention and to protect the identity of their sponsors and of the ultimate beneficiaries of the funds. Unlike laundering however, terrorist financing transactions tend to be in smaller amounts and thus, when they are derived from legitimate sources, the detection and tracking of these funds is more difficult.

Terrorist financing comes from two primary sources:

  1. Financial Support – financial sponsorship from like-minded countries, sympathetic governments, or individuals with sufficient financial means
  2. Revenue Generation – revenue generation typically involves criminal activities (i.e. the activities of criminal organizations).
  1. IC’s AML compliance regime operates on a risk-based approach and will include:1. Written Policies and Procedures: The AML Policy will be reviewed regularly to ensure that it is up to date and applicable to the activities of the firm. Several factors could trigger the need to update the AML Policy including changes in legislation, non-compliance issues, or the introduction of new services or products.Last Update: December 20133The AML Policy will be approved by Karen Azlen, the Chief Executive Officer (CEO) who is the Ultimate Designated Person (UDP) for IC. Although some senior officers may not be involved in day-to-day compliance, they understand the statutory duties placed upon them, employees and IC itself.2. Designation of the Canadian Anti-Money Laundering Officer (CAMLO): Amana Manori, the Managing Director, Chief Compliance Officer (CCO) & Chief Legal Officer (CLO) is the designated CAMLO. In the event that Amana Manori is unavailable, Karen Azlen will be the alternate CAMLO.The CAMLO is ultimately responsible for ensuring day-to-day compliance with the AML Policy; the assessment and documentation of risks for money- laundering and terrorist financing and measures to mitigate high risks; communicating the AML Policy to all employees, fulfilling reporting obligations.3. Risk Analysis:
    1. Risk Methodology: The risk methodology that IC applies to its business activities is as discussed in the FINTRAC guidelines. The assessment takes into account the following factors:
      • the clients and business relationships of the person or entity;
      • the products and delivery channels of the person or entity;
      • the geographic location of the activities of the person or entity; and
      • any other relevant factor.
    2. Risk Assessment: IC’s risk assessment is done in two stages: business- based risk assessment and relationships-based risk assessment of products and services. Both stages are determined to be VERY LOW upon reviewing the internal controls pertaining to IC’s clients and services it provides.
      The following very low/low risk factors have been considered:

      • IC does not directly hold clients’ subscription funds;
      • IC does not manage clients’ assets or perform any trading activity on behalf of clients;
    • IC does not managed any investment products in house; IC introduces clients to third party products and clients complete third party subscription documentation (i.e. clients subscribe directly to the third party opportunity);
    • IC does not deal with cash or in cash transactions of any kind, under any circumstances;
    • IC is a boutique firm in which the business volume including subscription quantity is limited;
    • IC’s client-base is easily identifiable and all client files include proof of identity;
    • IC is an Exempt Market Dealer (EMD) in Canadian offering jurisdictions and the majority of IC’s clients are Canadian; and
    • IC introduces eligible investors to vetted alternative opportunities – IC complies with Know Your Product (KYP) and Know Your Client (KYC) requirements to ensure quality products are introduced to suitable investors.

    c. Risk Mitigation: IC will take necessary risk mitigation measures including: confirming that necessary client identification is provided prior to the acceptance of investors; and ensuring that the AML policy and outlined compliance regime are strictly adhered to. IC will have:

     

    Effective internal controls such as:
    Customer identification, due diligence and KYC procedures;

    Operational assessment (products, services, clients and geographic locations) that are more vulnerable to abuse;

    Informing staff of compliance initiatives and identified compliance deficiencies;

    Developing operational continuity despite changes in management, employees or structure; and

    Striving to meet all regulatory record keeping and reporting requirements.

    General measures such as:

    Development, implementation and review of policies and procedures of IC’s AML Compliance Regime;

    • Appropriate monitoring of transactions;
    • Suspicious transaction reporting procedures; and
    • Assessment of employment structure to ensure that there are clear lines of authority, responsibility and accountability; appropriate training, segregation of employment duties and authorization processes; and internal reviews to validate the risk assessment processes.

    iii. Risk-focused measures such as:

    • seeking additional information to substantiate the client’s identity or the beneficial ownership;
    • obtaining additional documented information regarding source of funds;
    • requesting high risk clients to provide additional documented information to safeguard against money launderers and terrorists; and
    • seeking independent verification of information.
      4. AML Training: IC will have a written training program detailing the frequency, method, and the repercussions for failure or non-compliance. All employees will receive training upon hire and refresher training on an annual basis.
      The AML Policy will be distributed to all employees. It will be ensured that all employees understand and adhere to the AML Policy, particularly those who work in the areas relating to client identification, record keeping, and any of the types of transactions that have to be reported to FINTRAC.
      Employees will be made aware of circumstances where an enhanced level of caution is required in dealing with transactions, such as those involving countries or territories that have not yet established adequate anti-money laundering or anti-terrorist financing regimes consistent with international standards.
      5. Review of AML compliance regime: Every two years either the CLO or an independent internal or external auditor will conduct a comprehensive review of the effectiveness of IC’s AML compliance regime. This review will include an assessment of all policies, testing of procedures, client identification processes, training and overall risk assessment. Upon completion of the review, the scope of the review will be documented with detailed findings, recommendations and subsequent updates to policies/procedures. Upon 30 days of the completion of the review, a report to management will be produced and presented. Following the report, the CAMLO will respond with follow up actions in response to recommendations and timeline for completion.

    The last review was conducted in December 2013 upon which a risk report, recommendation report and final report to management was produced and presented to the UDP.

PCMLTFA defines a suspicious transaction as a “financial transaction that occurs in the course of (business) activities and in respect of which there are reasonable grounds to suspect the transaction is related to the commission of a Money Laundering offence and/or a terrorist activity financing offence”.

Determining suspicious transactions should be on evaluation of a number of factors and consideration of all surrounding circumstances. Industry specific indicators should be assessed. A single indication ma not necessarily provide reasonable grounds to suspect money laundering or terrorist financing. However, more than one may. Some common indicators are:

  • reluctance to provide adequate identification information upon subscription;
  • attempts to purchase units with cash, money orders, traveler’s cheques, cashiers cheques, foreign bank drafts or other bank instruments in amounts
    under $10,000; and
  • attempts to purchase securities with third-party instruments.
  1. 1. United Nations Suppression of Terrorism and United Nations Act Sanctions Reporting Requirements & Forms (UNSTR): The UN Regulations and the Criminal Code require IC to determine on a monthly basis whether they are in possession or control of property that is owned or controlled by, or on behalf of, anyone on the UN List by reporting to the firm’s principal supervisory or regulatory body. Names under the Criminal Code and UN Regulations have been combined into the lists currently posted on the Office of the Superintendent of Financial Institutions (OSFI) website.IC complies with the UNSTR. IC submits the UNSTR on a monthly basis (by the 14th of the month) to the Ontario Securities Commission (OSC) who is the principal regulator for IC.The UNSTR relate to terrorist financing and United Nations Act sanctions on certain countries under the following:
    • Criminal Code 
    • Regulations Implementing the United Nations Resolutions on the 
      Suppression of Terrorism 
    • United Nations Al-Qaida and Taliban Regulations 
    • Regulations Implementing the United Nations Resolution on the Democratic 
      People’s Republic of Korea 
    • Regulations Implementing the United Nations Resolution on Iran 
      The Consolidated Form: Monthly Suppression of Terrorism and UN Sanctions Report can be found on the OSC website at: http://www.osc.gov.on.ca/en/23323.htm.
      2. Suspicious Transaction Reporting: IC must report suspicious transactions to FINTRAC within 30 days of first detection. The CLO will complete the Suspicious Transaction Reports as per FINTRAC Guideline 3A and file them electronically with FINTRAC at: www.fintrac- canafe.gc.ca/publications/guide/Guide3A/str-eng.asp#s3-1. The Compliance Officer will also retain a copy of these reports for audit purposes. The appropriate law enforcement body will be contacted to report the suspicious transaction.
      IC employees cannot disclose that IC has made a suspicious transaction report, or disclose the contents of such a report, with the intent to prejudice a criminal investigation, whether it has started or not. No criminal or civil proceedings may be brought against a person for making a report in good faith.
      Suspicious transactions related to an attempted commission of money laundering or terrorist activity financing offence also have to be reported. For example, when a transaction – or a group of transactions – raises questions or gives rise to discomfort, apprehension or mistrust.
      3. Terrorist Property: Under the Act, IC is also required to file a Terrorist Property Report with FINTRAC if it has in its possession or control property that it (or an employee) knows is owned or controlled by a terrorist or a terrorist group or has knowledge of a proposed transaction that involves terrorist assets. In addition, there is also a requirement under the Criminal Code for anyone in Canada and any Canadian outside Canada to disclose to the Royal Canadian Mounted Police and the Canadian Security Intelligence Service the existence of property in their possession or control that they know is owned or controlled by or on behalf of a terrorist or a terrorist group. It is an offence under the Criminal Code to deal with any property if you know that it is owned or controlled by or on behalf of a terrorist or a terrorist group. It is also an offence to be involved in any transactions in respect of such property. IC is required to file with the OSC a monthly report under the United Nations Suppression of Terrorism Regulations.

    A consolidated list of the names of suspected terrorist organizations and individuals published under the Regulations Establishing a List of Entities made under the Criminal Code or the United Nations Suppression of Terrorism Regulations is found at the OFSI website: http://www.osfi- bsif.gc.ca/osfi/index_e.aspx?DetailID=627

     

 

In accordance with IC’s policy on Books and Records, IC will maintain all client account records created in the normal course of business in a safe and secure location. In addition, all AML related reports including suspicious transaction reports would be maintained.

Records will be maintained in a format and location that will permit them to be provided to FINTRAC within 30 days of request. Records will be maintained for a minimum of seven years.

Under the Act, IC must take steps to identify every person who is authorized to give instructions for an account, as well as ascertain the identity of the beneficial owner of the investment. The identity of said beneficiary must be verified within six months of the time the subscription is received. IC will collect the following identification for clients in order to comply with the AML Policy:

To identify an individual, IC will refer to the individual’s birth certificate, driver’s license, passport, record of landing, permanent resident card or other similar document.

Complete and detailed information regarding the client’s occupation is mandatory. If an individual is self-employed, the nature of the business must be provided. If the client is retired, the client’s previous employment should be noted.

To open corporate accounts, IC will require identify of all individuals who beneficially own more than 10% of that corporation, whether directly or indirectly. This involves obtaining the name, address, citizenship, occupation and employer of each beneficial owner and whether he or she is an insider or controlling shareholder of a publicly traded corporation or similar entity.

IC will also need to verify the identity of owners via collection of the names and occupations of all directors and a certificate of corporate status. Corporate resolutions are also required as evidence of who is authorized to trade in the account – the identity of which also must be verified.

 Employees must be alert as to whether or not a third party is the beneficial owner of a new account or fund investment. IC and its personnel are required to take reasonable measures to determine whether or not the new client or fund investor is acting on behalf of a third party. If IC personnel have any grounds to suspect that the client or fund investor is acting on behalf of a third party, he or she must report this situation immediately to the CLO. The CLO will be responsible for maintaining a record to indicate whether, according to the client, the transaction is being conducted on behalf of a third party, and to indicate details of why it is suspected that the client is acting on behalf of a third party.

IC will need the identity of the settlor and all individual beneficiaries of more than 10% of the trust or account, whether directly or indirectly. IC will need the name, address, citizenship, occupation and employer of each and whether any is an insider or controlling shareholder of a publicly traded corporation or similar entity. Exceptions can be made for some beneficiaries such as minor children.

As support of the trust, a written trust agreement, other trust documents or a trust information form are will be requested. IC will also identify and verify the identification of all trustees of the trust.

Informal trusts, including personal trusts, will mandate a record about each of the beneficiaries. The information required in this record is the name, address and principal business and occupation of each beneficiary known at that time. If the beneficiary is an individual, the record also has to include the beneficiary’s date of birth and social insurance number.

For non-individual entities other than corporations and trusts, IC will request their constating documents including details of all beneficial owners holding a 10% interest. For example, IC may refer to a partnership agreement, articles of association or any other similar record that confirms the entity’s existence.

Valid foreign documents are required for the identification of non- Canadian investors equivalent to an acceptable type of Canadian identification document such as a valid foreign passport. Advisors should be mindful that non- Canadian clients would only be permitted from jurisdictions where IC and its advisors are registered or permitted to sell under an eligible exemptions.

Individual clients will be required to certify, through the new account application forms or initial client account documentation, that they are not Politically Exposed Foreign Persons.

A politically exposed foreign person is an individual who holds or has ever held one of the following offices or positions in or on behalf of a foreign country: a head of state or government; a member of the executive council of government or member of a legislature; a deputy minister (or equivalent); an ambassador or an ambassador’s attaché or counsellor; a military general (or higher rank); a president of a state-owned company or bank; a head of a government agency; a judge; or a leader or president of a political party in a legislature.

This certification extends to the client’s immediate family as well (such as: mother or father; child; spouse or common-law partner; spouse’s or common-law partner’s mother or father and brother, sister, half-brother or half-sister (that is, any other child of the individual’s mother or father). An individual or family member is a politically exposed foreign person regardless of their citizenship, residence status or birthplace.

If it is determined that an individual is a politically exposed foreign person for a new account, IC will

  1. get the CEO’s approval to keep the account open within 14 days after the new account is activated;
  2. take reasonable measures to establish the source of funds that have been, will be or are expected to be deposited in that account.; and
  3. performenhancedongoingmonitoringofactivitiesforthataccounttodetect suspicious transactions.

IC will do check existing client accounts to determine whether existing clients are politically exposed foreign persons.

    1. Agent/Mandatory: When collecting identification, the original document must be presented to IC personnel or a representative thereof. If face-to-face collection is not possible, an agent or mandatory may be used to verify the original document. Prior to using an agent/mandatory, IC will have to enter into a written agreement or arrangement with the agent or mandatory. In addition, IC will have to obtain from the agent or mandatory the customer information that was obtained according to the agreement or arrangement. 
    2. Individual is not Physically Present: To identify an individual who is not physically present will have to use one or the other of the following options to confirm the identity of that individual:
      OPTION 1: Affiliate or co-member. IC will first obtain the individual’s name, address and date of birth. Then confirm that one of the following has identified the individual by referring to an original identification document: 
      a financial entity, life insurance company or securities dealer; or, an entity affiliated with IC and whose activities outside Canada are similar to those of a financial entity, life insurance company or securities dealer. An affiliated entity is one that either IC fully owns or that fully owns IC, or both fully owned by the same entity.

    OPTION 2: Combination of methods. To identify an individual using this second option, IC will have to use a combination of two of the methods noted below. In each of the two methods used, the individual’s information has to be consistent with what is in IC’s records. The information also has to be consistent from one method to the other.

    The methods below may not apply for all clients. For example, the methods would not be available to identify a client outside Canada who is opening an account but has no Canadian credit history, no access to a Canadian guarantor and no deposit account with a financial entity. In this case, identification of the client using an identification document may necessitate the use of an agent or mandatory, as explained above.

    a. Identification product or credit file method

    • Refer to an independent and reliable identification product. It must be based on personal information as well as Canadian credit history about the individual of at least six months duration. This type of product can use a series of specific questions, based on an individual’s credit file, to enable verification of client identity.
    • With the individual’s permission, refer to a credit file. The credit file must have been in existence for at least six months.
      b. Attestation method: Obtain an attestation that an original identification document for the individual has been seen by a commissioner of oaths or a guarantor. The attestation must be on a legible photocopy of the document and include the following information:
    • the name, profession and address of the commissioner of oaths or the guarantor;
    • the signature of the commissioner of oaths or the guarantor; and
    • the type and number of the identifying document provided by the
      individual being identified.
      In this context, a guarantor has to be an individual engaged in one of the following professions in Canada: a dentist, a medical doctor or a chiropractor; a judge, a magistrate or a lawyer; a notary (or a notary public; an optometrist or a pharmacist; an accredited public accountant (APA), a chartered accountant (CA), a certified general accountant (CGA), a certified management accountant (CMA), a public accountant (PA) or a registered public accountant (RPA); a professional engineer; or a veterinarian.

    c. Cleared cheque or deposit account method

    • Confirm that a cheque drawn on a deposit account that the individual has with a financial entity has cleared. This means a cheque that was written by the individual, cashed by the payee and cleared through the individual’s account. It does not include pre-authorized payments as these are not cheques written by the individual.
    • Confirm that the individual has a deposit account with a financial entity.

IC does not accept cash transactions and will reject any prospective client that wishes to transact in cash. Business will only be conducted through recognized financial entities.

  • Any employee who knowingly assists in money laundering activities will be liable to criminal prosecution and summary dismissal for cause. There are criminal and administrative penalties for non-compliance. Both criminal penalties and AMPs will not be issued against the same instances of non-compliance.
    Criminal penalties for non-compliance include, but are not limited to:
  1. Failing to retain records: Fine of up to $500,000 and/or imprisonment up to 5 years.
  2. Failing to report a suspicious transaction: Fine of up to $2,00,000 and/or imprisonment up to 5 years.
  3. Tipping (disclosing that a suspicious transaction report was made, or the contents of the report): Imprisonment up to 2 years.
  4. Failing to report a prescribed transaction: Fine of up to $500,000 for the first offence and up to $1,000,000 for each subsequent offence.

For any of the foregoing offences, any officer, director, or agent who directed, authorized, acquiesced or participated in the commission of the offence may also be deemed guilty of the offence.

Administrative monetary penalties (AMP) for non-compliance carry maximum penalties for individuals and entities (e.g. corporations), as reflected in the list below:

Last Update: December 2013

13

  1. Minor (individual/entity):
  2. Serious (individual/entity):
  3. Very Serious (individual):
  4. Very Serious (entity):

$1 to $1,000 $1 to $100,000

$1 to $100,000

$1 to $500,000

Employees do not need to be actively involved in a money-laundering scheme to face liability. A person who has knowledge of the tainted source of funds but still effects a transaction involving such funds may be charged with money laundering. As such, facilitating a financial transaction while wilfully or recklessly disregarding the source of the customer’s assets or the nature of the customer’s transactions can also result in criminal and/or civil liability for both employees and IC.

It is unlikely that a person or entity will be charged or convicted for an offence under the Act and the Regulations if they exercised proper due diligence to prevent its commission. Moreover, no criminal or civil proceedings will be brought against a person or entity for making a report under the Act in good faith to the appropriate regulatory body. For these reasons, compliance with the AML Policy is essential for the protection of both IC and all of its directors, officers and employees.

The limits above apply to each violation, and multiple violations can result in total fines that exceed these limits.

For more information on the AML Policy, please contact Amana Manor, the CAMLO.

FINTRAC Guidelines can be found at: http://www.fintrac-canafe.gc.ca/publications/guide/guide-eng.asp

Introduction Capital Inc. (IC) Anti-Money Laundering and Anti-Terrorist Financing Policy (AML Policy) is created to demonstrate IC’s commitment to prevent, detect and address non-compliance in regards to money laundering and terrorist financing activities. IC will not knowingly participate in any capacity in the advancement of a transaction that is suspected to be related to the commission of a money laundering or terrorist financing activity.

IC’s AML compliance regime operates on a risk-based approach (RBA). In the context of money laundering and terrorist financing, a RBA is a process that encompasses the following: IC’s risk assessment using certain factors; the risk-mitigation to implement controls to handle identified risks; keeping client identification and beneficial ownership information up to date; and the ongoing monitoring of financial transactions.

IC’s AML Compliance Regime is comprised of five key areas:

  1. Written Policies and Procedures
  2. Designated Canadian AML Officer (CAMLO)
  3. Risk Analysis
  4. AML Training 
  5. Review of AML Compliance Regime

IC’s Anti-Money Laundering and Anti- Terrorist Financing Training Policy (AML Training Policy) is designed to focus on the fourth key area of IC’s AML Compliance Regime. All employees should understand and adhere to the AML Policy, particularly those who work in the areas relating to client identification, record keeping, and any of the types of transactions that have to be reported to FINTRAC.

The CAMLO will be responsible for designing and/or adopting an AML training module that will be rolled out to all employees including officers, directors, administrators and sales people. Currently, as there are only two full- time partners at IC, the CCO will be responsible for training the CEO on IC’s AML Compliance Regime.

IC’s AML training will review Canada’s AML regime in general including definitions of AML and ATF.

Employees will be made aware of circumstances where an enhanced level of caution is required in dealing with transactions, such as those involving countries or territories that have not yet established adequate anti-money laundering or anti-terrorist financing regimes consistent with international standards.

AML training will address specific instances of money laundering and terrorist financing that employees may face in their roles at the firm.

The CCO will conduct individual non-written training but may adopt a written AML training format or implement an on-line training module at a later date.

If written training is implemented to review and discuss AML in Canada and potential incidents that may employees may face, there will be an examination or quiz. Employees will be required to have a pass mark of at least 80% to successfully complete the training. Employees who fail to achieve a mark of 80% or higher will be asked to redo the AML testing. The quiz will be modified on an annual basis to ensure new questions will be included each year.

All Employees will receive training upon hire and refresher training on an annual basis. In addition, the CAMLO may administer additional training as she sees fit (i.e. if there is an instance that warrants special attention or if there has been a change in the legislation).

IC’s AML training and corresponding AML Training Policy will be reviewed on an annual basis for relevance.

AML training is mandatory. There will be serious repercussions for employees who fail to participate in the training and testing. Employees who are unable to complete the training during the timelines set by the CAMLO should make alternate arrangements. Employees should know that there are criminal and administrative monetary penalties for non-compliance with AML and ATF rules and regulations.

For more information on the AML Policy, please contact the CAMLO: Ms. Amana Manori.

FINTRAC Guidelines can be found at:

http://www.fintrac-canafe.gc.ca/publications/guide/guide-eng.asp