IIAC REQUESTS REVISIONS TO THE QI ATTACHMENT FOR CANADA TO REFLECT AMENDMENTS TO THE PCMLTFA
The IIAC wrote to the U.S. Internal Revenue Service (IRS) to request revisions to the current Qualified Intermediary Agreement (QI Agreement) Attachment for Canada to reflect legislative amendments made to the Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) in 2019 in order to ensure Canadian QIs are able to utilize the more flexible identification rules.
The government identification verification requirement was amended from requiring a document that was “original, valid and current” to “valid, authentic and current”. This means that a financial institution (FI) can have government identification presented via electronic means rather than requiring the FI to view the document personally, if the FI has the technology to authenticate the document. While the PCMLTFA rules were expanded and modernized for all Canadian FIs, FIs that are also QIs are unable to benefit from the modernization. The IIAC’s proposed changes to the Attachment for Canada would ensure Canadian QIs are not unfairly disadvantaged from developing more innovative onboarding processes.
For more information, please contact Adrian Walrath.