Canada: corporate life-insurance onboarding

FINTRAC's information-record rules cover a policy or annuity for which the insurer is to receive C$10,000 or more over its duration, or remit C$10,000 or more to a beneficiary. Apply the relevant identity-verification timing and product exceptions. Large cash, virtual-currency and suspicious transactions have separate triggers.

Verify the corporate policyholder

For a corporation requiring verification, obtain evidence of its existence, name, address and directors using an accepted method. The Canadian registry guide explains the federal and provincial searches. Obtain the names and addresses of individuals owning or controlling at least 25%, the ownership structure and reasonable measures confirming that information's accuracy.

Record the authorised applicant, insured person, payer and beneficiaries. Obtain the mandate for the company's purchase and any assignment affecting policy rights.

Beneficiaries and exempt products

Where an information record is required for a beneficiary, apply the verification requirements before the first remittance and the associated timing provisions. Record the recipient's entitlement and investigate instructions to pay a different party.

Certain products, including qualifying group life policies without cash surrender value or a savings component, have identification exceptions. These do not remove the separate requirements for large cash, large virtual-currency or suspicious transactions.

Review unusual premiums, assignments and surrender requests through ongoing monitoring. FINTRAC's guidance distinguishes keeping identification information current from repeating the original verification method; obtain new verification where the earlier information is doubtful.