Today's Mortgage Choice Anti-Money Laundering, Anti-Terrorist Financing and Sanctions Compliance Policy and Procedures


Today’s Mortgage Choice is an entity that is authorized under provincial legislation to act as a mortgage brokerage (the Brokerage). The Brokerage employs individuals who are authorized under provincial legislation to act as mortgage agents (the Agents).1 On behalf of the Brokerage, the Agents help borrowers find suitable mortgages by collecting borrower data and sharing it with various potential lenders. The selected lender then works with the borrower to fund and complete the mortgage. Once the mortgage is completed, the lender pays a commission for the benefit of the Brokerage and Agent.

Since the Brokerage and Agents are authorized under provincial legislation to act as intermediaries between a lender and a borrower with respect to loans secured by mortgages on real property or hypothecs on immovables, the Brokerage and Agents fall within the definition of “mortgage broker” for the purposes of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the PC Act). Mortgage brokers are subject to the requirements of the PC Act because they are engaged in a business or profession for the purposes of paragraph 5(i) of the PC Act.2 As individuals and entities in Canada, the Brokerage and Agents are also subject to Canadian sanctions legislation.

PURPOSE OF AML POLICY

The Brokerage has established these anti-money laundering, anti-terrorist financing and sanctions compliance policy and procedures (AML Policy or Policy) to comply with the requirements of the PC Act and Canadian sanctions legislation and to set out the measures that the Brokerage has implemented in respect of its operations to prevent the misuse of its products and services to launder money, finance terrorist activities, or contravene Canadian economic sanctions (AML Program).

Money laundering, terrorist financing, and sanctions violations are significant problems facing governments and payment service providers around the world. To combat these problems, Canada has enacted laws that require financial institutions, money services businesses and other financial intermediaries to detect and help prevent money laundering, the financing of terrorism, and sanctions violations.

Money laundering, terrorist financing, and sanctions violations also present risks to the Brokerage. The reputation of the Brokerage can be significantly damaged as a result of any association with money laundering, terrorist financing, or sanctions violations. In addition, the Brokerage and Agents can face penalties for failing to comply with applicable Canadian requirements. Potential penalties include criminal prosecution, costly and public civil penalties, and regulatory enforcement actions.

For a full copy of our Anti-Money Laundering, Anti-Terrorist Financing and Sanctions Compliance Policy and Procedures, please download it here.