AML Requirements for Renewals

FINTRAC recently put out guidance specific to the mortgage sector to our clarifying our requirements on

renewals.

In short, all the same requirements that you’d complete on a new file (ID Verification, Risk Assessment

and Justification, PEP Screening, and Sanctions Screening) must be completed on all renewals.

If it is an existing client for whom you’re doing a renewal, you can avoid the ID Verification step only if

the records for the ID were properly retained (as noted on FC’s updated KYC), the ID has not expired,

and there is no new information to suggest that the information is out of date or incorrect.

For those agents using Velocity, this includes re-screening your clients against Sanctions List – if you’re

not pulling credit on the file and are unfamiliar with how to do this manually, please reach out to the

compliance team.

For those agents using Filogix, this means that you’ll need to pull a new Equifax AML Assist to document

PEP and Sanctions screening.

For Agents/Brokers on both platforms, we strongly encourage the online Interactive Risk Assessment

Scorecard developed by DLCG to document your Risk Rating. If you’re still unfamiliar, the tool can be

found here.

These requirements will now be reviewed as part of the compliance process – if you have any questions,

please reach out to your AML Officer (james@fcfunding.ca).