As part of our efforts to ensure compliance with our anti-money laundering obligations, we find that we do not always have the source of funds on file for deposits or bank transfers received from clients, in amounts of $50,000 or more, whether for non-registered or TFSA plans. It is important to remember that the source of funds must be documented in the dealer’s records upon receipt of the sums.
For this purpose, you can indicate the source of funds in the form of a note in Univeris, either in OrderXPRESS or under the Plans / Details / Notes tab, or the Clients / Communications / Notes tab.
Please ensure that your notes clearly include the deposit amount and are sufficiently detailed to avoid compliance inquiries. Even if the amounts come directly from the client’s bank account, the requirements require that the source of the invested sums be documented. Here are examples of sources of funds: business income, sale of a residence, inheritance, accumulation of income, etc.
As a reminder, if a purchase or a deposit is made using a bank draft or non-personalized cheque, we ask that you please provide the appropriate documentation to confirm that the funds are taken from the client’s bank account. In the case of third-party cheques (e.g., from the client’s employer or company), additional supporting documentation must always be provided, and a copy of the cheque or draft must be sent to the imaging system for dealer records.
We thank you for your attention.
Should you have any questions or require additional information regarding this memo, please do not hesitate to contact your Compliance team.