Anti-Money Laundering (AML)
What transactions are prohibited for non-customers?
-Purchase/Sale of Precious Metals
-Sending Wire Payments
-Purchase of a Bank Draft
-Cashing of business/personal drafts
Where would you go to update contact preferences?
-Go to CIF MCCP to complete the update
If a customer presents a cheque for $25 million issued from RBC, can we complete the deposit?
No, an alternate payment arrangement, such as a wire, must be made by the customer
What Transactions are permitted for non-customers?
-bill payments, OFI credit cards $9999
-cash federal government cheques $1750/item
-cash/coin exchanges $2999
-sale of commemorative coins $2999
-cash foreign exchange $2999
-cash deposits to a TD account $9999
-cash payment to TD credit card/other credit products $9999
What happens when a customer makes a request to access their personal information?
-Complete the Personal Information Access Request Form (PIAR), Form 800662, and email the request to TD.PIAR@td.com
-Let the customer know that the information will be sent to them by registered mail within 30 calendar days
When would you provide a Letter of Refusal?
You must provide the customer with Form 522048 - Letter of Refusal if the first $100.00 is not made available to the customer; provide it in person if they are in the branch or by mail if they have left. The reasons are listed below:
-Cash the Federal Government cheque or other payment instrument presented by you for payment' if you are refusing to cash the cheque presented
-Make the first $100 of funds deposited by cheque or other instrument to your personal deposit account available to you for withdrawal' if you are not making $100 available for withdrawal
-Make available for withdrawal funds deposited by cheque or other instrument to your personal or business account within the time period set out in our Hold Funds Policy
Under what circumstances would you submit a Large Currency Transaction Report (LCTR)?
-For all incoming cash transactions of $10,000 (CAD) or more in the course of a single transaction
-In S3, you will be automatically prompted to complete an LCTR when you have received $10,000 CAD equivalent or more in the course of a single S3 session
What happens when a customer requests to add/modify their contact preferences for electronic marketing?
-Access and complete the Enterprise Permissions Center Tool (EPC Tool) from B-web
What form must be completed for large cash withdrawals? What section should the customer sign on in this form?
-Release of Liability Form must be completed for large cash withdrawals
-Customer initial section 3 of the form acknowledging fraudsters may ask their victims to mail cash, deposit cash to fraudsters account, send funds internationally
Under what circumstances and when would you submit an Unusual Transaction Report (UTR)?
-If you have concerns that activity may be potentially related to money laundering or terrorist financing
-You must complete an UTR regardless of whether the customer completed the transaction or only attempted to complete it
-An 'Unusual Transaction Report' must be filed whenever you feel a transaction, regardless of the amount, is unusual for your customer
How and when do you report a privacy event?
-If you have identified, been informed of, or suspect that a privacy event involving customer or employee information has occurred; you must escalate to management immediately
-Complete Privacy Event Notification Form and send form to TD.CPBPrivacyEvents@td.com and they will reach out within 2 business days
What are the eligibility requirements for submission of a cheque to CVS?
The following eligibility conditions must be met:
-The cheque is a minimum of $10,000 (CAD or USD)
-The cheque must be payable to the registered name on the deposit account (CIF)
-The cheque must be issued from a business account
-The cheque issuer must originate in Canada or USA
-The appropriate hold must be lodged
What classifies someone as a Politically Exposed Person (PEP)? What should be completed if a customer self-identifies as a PEP?
An individual who holds or has ever held one of the following offices or positions in or on behalf of a foreign country, which may include:
-Head of state or government, Member of the executive council of government or member of a legislature, Deputy minister (or equivalent), Ambassador or an ambassador’s attaché or counselor, Military officer with the rank of general or above, President of a state-owned company or state-owned bank, Head of a government agency, Judge, Leader or president of a political party in a legislature
-Complete Form 529892/529893. In cases where the form is completed, it must be submitted to GAML within 24 hours
How do you remove a customer/non-customer from the Do Not Call List (DNCL)?
Access and complete the Enterprise Do Not Call System on b-web
When would access to funds requirements not apply?
-The account has been opened for less than 90 days
-The cheque(s) is double endorsed
-The cheque(s) is stale dated
-Cheques that are not issued in Canadian dollars
-Cheques that are drawn on an institution outside of Canada
-You have reasonable grounds to believe the cheque is being deposited for fraudulent purposes. This could include a sudden increase in the number of cheques negotiated by a Personal Customer without a reasonable explanation