Compliance Memo

CM_2021-03; Anti-Money Laundering & Terrorist Financing Manual Update

For more information, contact:

Compliance Team

Date Issued:

November 12, 2021

The Anti-Money Laundering Policy has been updated to align with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act changes that came into force on June 1, 2021. 

Below is a summary of the notable additions and updates:

  1. The definition of Politically Exposed Person has been updated and separated into Politically Exposed Domestic Person and Politically Exposed Foreign Person.
  2. The definition of Head of an International Organization (HIO) has been updated to:
    a) include international sports organizations.
    b) exclude removal of a person as an HIO.
  3. The requirements to ascertain a client’s identity have been updated as follows:
    a) the identification document (ID) referred to must authentic, valid, and current, and contain the person’s photograph. Examples of such documents have been updated to reflect what each province or territory of Canada currently issues.
    b) credit file method has been updated to clarify the requirements.
    c) dual-process method has been added along with examples of the documents that can be used as acceptable pieces of ID
    d) other methods of identification that are no longer in force have been removed.
  4. Confirmation of existence of a corporation or an entity has been updated to reflect minor changes.
  5. Money Laundering and Terrorist Financing Indicators have been updated to reflect a securities-dealers’ specific indicators.
  6. Cash equivalents list has been expanded to include virtual currency.
  7. Record keeping requirements have been updated to specify requirements for each identification method used.
  8. The list of Consequences for Non-compliance has been expanded.

For your reference, you can click the link below to access the updated manual:

Please take the time to familiarize yourself with the updated policy.

As always, if you have questions or comments, contact the Compliance Department by email at