AML Program

TriCert Financial Group Inc. and its subsidiaries, TriCert Investment Counsel Inc. (“TriCert IC”) and TriCert Life Insurance Agency Inc. (TriCert IA) (collectively referred to as “TriCert”, “we”, “our”) are firmly committed to maintaining an effective Anti-Money Laundering/Anti-Terrorist Financing (“AML/ATF”) and Sanctions program (collectively referred to as the “AML Program”) designed to deter, detect and report suspicious activity, including the misuse of its products, services and delivery channels related to Money Laundering (“ML”) and/or Terrorist Financing (“TF”), bribery and corruption, and/or other activities that may violate applicable economic sanctions.

Governance Framework

TriCert IC’s Chief Compliance Officer (“CCO”) maintains oversight and is responsible for the overall design, content and operation of the firm’s AML Program. The CCO has direct access to, and regular communication with, TriCert IC’s Ultimate Designated Person (“UDP”) and the TriCert Board (“Board”), providing them with regular updates on the operations and effectiveness of the firm’s AML Program.

The AML Program follows a three (3) lines of defence risk governance framework to help mitigate the risk of TriCert’s products or services being used to fund financial crime and to ensure compliance with applicable laws and regulations across the multiple jurisdictions in which we operate.

First Line of Defence: Business lines develop and maintain appropriate processes and controls to manage the risks associated with their day-to-day activities according to established AML/ATF and Sanctions policies and standards.

Second Line of Defence: TriCert IC’s Compliance team provides oversight of the AML Program, offering expertise and guidance across all business lines.

Third Line of Defence: External auditors provide enterprise-wide assurance to Senior Management and the Board on the effectiveness of TriCert’s AML Program.

Policies and Procedures

TriCert maintains documented policies and procedures that outline expectations and requirements to assist in complying with applicable legal and regulatory obligations in the jurisdictions in which we operate. Where local legal or regulatory requirements differ from enterprise policies and procedures, employees must follow the stricter standard.

All policies and procedures are published internally and accessible to all employees. Policies and procedures are subject to periodic review for updates and are approved by TriCert IC’s CCO.

Risk Management

The risk management principles that govern our management of ML/TF and Sanctions risks include:

• • To accept as clients only those individuals and legal entities whose identity and ownership can be adequately ascertained and whose activities can reasonably be established to be legitimate;
  • To not knowingly provide any form of financial services to clients whose money is believed to be derived from the proceeds of crime or activity that violate sanctions, or whose money is believed to be intended for use for illegal activities;
  • To perform enhanced due diligence reviews on individuals or legal entities identified as having a higher risk;
  • To cooperate with regulators and law enforcement agencies in accordance with applicable law;
  • To assess and document the risk of ML/TF and sanctions across the organization and evaluate the controls in place designed to mitigate such risk; and,
  • To review new products, services, and delivery channels, as well as significant changes to any of them, to ensure that the associated ML/TF risk is within the firm’s risk appetite and that appropriate internal controls are in place to mitigate identified risk.

TriCert has no appetite to allow its products or services to be used to facilitate money laundering, terrorist financing, human trafficking, or any activity that is prohibited by laws and regulations, including sanctions.

Client Due Diligence

TriCert periodically conduct searches of its client base against lists of known or suspected terrorists and sanctioned parties. These reviews are completed to also identify Politically Exposed Persons (PEPs) or Head of International Organizations (HIOs) which require enhanced due diligence and monitoring. Other clients identified as having higher ML/TF risks are also subjected to risk-based enhanced measures.

Monitoring and Reporting

We take a risk-based approach to the level of monitoring conducted on client activity to identify and report potentially suspicious and/or unusual activity, or otherwise reportable transactions and attempted transactions. Where required, TriCert will complete the necessary reporting with the relevant regulatory authorities.

Training Program

TriCert maintains a comprehensive mandatory training program which is reviewed annually and updated with current AML/ATF and Sanctions legislation, regulatory requirements and enterprise policies and procedures. All employees, as well as those who act on our behalf, are required to complete AML/ATF and Sanctions focused training when joining the firm or annually thereafter.

Record Retention

As a part of the AML Program, we maintain records of all relevant AML/ATF and sanctions-related documents as required by applicable laws.