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CI Investments Inc. Submission in Response to Finance Canada's Enhancing Canada's Anti-Money Laundering and Anti-Terrorist Financing Regime consultation:
September 30, 2005
Department of Finance
140 O'Connor Street
Attn: Diane Lafleur – Director, Financial Sector Division
Enhancing Canada's Anti-money Laundering and Anti-terrorist Financing Regime
We are responding to your request for comments with respect to the Consultation Paper "Enhancing Canada's Anti-Money Laundering and Anti-Terrorist Financing Regime" published for comments by the Department of Finance on June 30, 2005.
In reading through the proposals, we observe that no clear distinction is made between mutual fund dealers (who do have direct client contact) and mutual fund manufacturers (whose client contact is not direct, but through a dealer). We therefore assume that mutual fund manufacturers will continue to rely on the mutual fund dealers' compliance in terms of the proposed requirements, such as records and client identification as outlined in your Proposals 1.8 and 1.9, respectively. Clarification on this point would be appreciated.
With regard to Proposal 3.2, there does not appear to be a validation process prior to disclosing an alleged "offender" on FINTRAC's website. As reputational damage resulting from erroneous website disclosure can be substantial, we suggest that prior to disclosing an offender, a verification process be followed to ensure that a suspected offender is indeed guilty of the offence. We further recommend that a suspected offender be notified and given an opportunity to respond.
We look forward to further dialogue between the Department of Finance and industry participants, specifically to gain greater clarity on the potential effects on the mutual fund manufacturers component of the industry.
We thank you for considering our comments.
CI INVESTMENTS INC.