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Bermuda Monetary Authority Fines Sun Life Financial Investments (Bermuda) Ltd $1,500,000 And Restricts Licence

27 February 2017

HAMILTON, BERMUDA - Bermuda Monetary Authority (the Authority) has imposed civil penalties totalling $1,500,000 on Sun Life Financial Investments (Bermuda) Ltd (the Company) pursuant to the provisions of section 20 of the Proceeds of Crime (Anti-Money Laundering & Terrorist Financing Supervision & Enforcement) Act 2008, and restricted the Company’s Investment Business licence pursuant to section 20 of the Investment Business Act 2003. 

The civil penalties have been imposed for the Company’s failure to comply adequately with the following requirements of the Proceeds of Crime (Anti-Money Laundering & Anti-Terrorist Financing) Regulations 2008 (the Regulations):

i) The application of Customer Due Diligence (CDD) measures;

ii) Ongoing monitoring of business relationships;

iii) Ceasing transactions where it is not possible to apply CDD measures;

iv) The application of Enhanced Due Diligence; and

v) The establishment and maintenance of appropriate and risk sensitive policies and procedures.

Some of the findings represented failings of the Company to adequately remediate similar findings from an onsite review conducted in 2013. The Authority views these breaches as serious because of their extent and duration, and because they demonstrated systemic weaknesses in the Company’s internal AML/ATF controls. The Regulations have been in effect since 2009. 

This case highlights the importance of licensees having in place up-to-date AML/ATF policies and procedures which are appropriate, effective and fully implemented in order to avoid the risk of financial products being used as a vehicle for money laundering or terrorist financing. 

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