PROCEEDS OF CRIME (MONEY LAUNDERING) AND TERRORIST FINANCING ACT – AMENDING REGULATIONS
On March 13, the IIAC submitted a comment letter to Finance Canada regarding Regulations Amending the Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
The IIAC highlighted an earlier joint submission made by the IIAC and CBA to the Department of Finance regarding the need of equivalency between record keeping obligations for securities dealers as compared to financial entities (FEs). Currently, subsection 29(b) of the Regulations has a broader requirement for securities dealers, obligating these entities to keep a record of the name and address of each account holder and every other person who is authorized to give instructions in respect of the account. The requirement for FEs is to keep a record of up to three persons who are authorized to give instructions in respect of the account. The IIAC indicated that there is no policy rationale for this difference and would be unduly burdensome for securities dealers.
For more information, please contact Michelle Alexander.