Compliance Questionnaire - Accountants sector

Part A

---

If operating as a sole practitioner: Your name and address:
If answering as a partner, administrator or employee: Organization’s legal name and operating name:
Head Office address:
Entity legal status (Select one only): Partnership, Limited Liability Partnership (LLP), Corporation,(If other, specify __ )
Please indicate the type of premises for the above address: Commercial / Retail, Residential / Dwelling House, or (If other, specify)
Name and title of the individual completing questionnaire:
Contact information:
Business telephone:
Business fax:
E-mail:

A1 - Since June 12, 2002 and at any moment, have you (operating as a sole practitioner) or your organization (for which you are a partner, administrator or employee) engaged in¹ or given instructions², in respect to any of the following activities carried on behalf of another person or entity (other than your employer): Receiving or paying funds³, Purchasing or selling securities, real property, business assets or entities, Transferring funds or securities by any means

No. None of the above activities apply (PLEASE COMPLETE THE FIRST PAGE AND RETURN TO FINTRAC)

If you answered yes, please provide a summary of the above activities you are engaged in and under what circumstances.

¹ Engaged in means to carry out the described activities. However, this does not mean that a formal engagement letter needs to be drawn, or fees charged to be "engaged in" one of those activities. If an accountant carries out the activities, he/she is covered.

² Given instructions means to provide specific direction (i.e., direct XX dollars to account number XXX in the Country Y, etc.). Giving advice is not considered to be equivalent to giving instructions.

³ Receiving or paying any funds on behalf of a client means an accountant is covered. One common example would include a firm or accountant receiving funds in trust to pay bills on behalf of a client.

If you are operating as a sole practitioner, please proceed to question A9, otherwise please continue to question A2.

A2 - Does your organization operate in any other location?

A3 - If you answered yes to question A2, indicate the name and address. If there is not enough room below, attach a separate sheet to provide all the relevant information, indicating that this information belongs in answer A3.

A4 - Is your organization a fully owned subsidiary of any other entity subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If so, what is the name and address of the parent organization?

A5 - Does your organization own any other entities that are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If so, what are the names and addresses of these entities? If there is not enough room here, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A5.

A6 - Does your organization, have an office outside of Canada?

A7 - If you answered yes to question A6, list in which countries? If there is not enough room here, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer A7.

A8 - Indicate the number of professional accounting members in your (check the appropriate box) organization: Number: CA/CGA/CMA

A9 - In which provincial/territorial accounting association(s) are you or your organization registered? (Check all that apply): CA, CGA. CMA. Other

A10 - Do you or your organization operate in a public practice setting?

A11 - What is your or your organization's primary bank / credit union / caisse populaire / trust company? (Please provide name and address)

A12 - What is your or your organization’s secondary bank / credit union / caisse populaire / trust company? (Please provide name and address)

A13 - Are you or your organization engaged in any other activities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? (e.g. foreign exchange, funds transfer, real estate, etc.). If so, please list.

A14 - Indicate in what type of business you or your organization operates and the approximate annual % of activity (gross revenue) it represents. (Check all that apply) Annual % : External audit/review/compilation , Accounting and bookkeeping, Management/administration , Bankruptcy/receiverships, Tax services/consultant, Financial planning, Compliance review, Forensic accounting, Computer consulting, Trust services, Other

A15 - What is your or your organization's approximate annual volume of business in $ (in relation to the activities described in question A14)?

A16 - Have you or your organization been subject to an anti-money laundering compliance review by your professional association since June 12, 2002?

Part B

---

B1 - Have you or your organization fully implemented a compliance regime in your organization? Refer to FINTRAC's Web site Guideline 4 at http://www.fintrac-canafe.gc.ca/publications/guide/Guide4/4-eng.asp

B2 - If you answered no to question B1, at what stage of implementation is your or your organization's compliance regime? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer B2.

B3 - Has a compliance officer been appointed to meet your or your organization's reporting, record keeping and client identification obligations?

B4 - If you answered yes to question B3, please provide the name of the compliance officer.

B5 - Does your compliance officer report directly to senior management of the organization? (Senior management could be the owner or chief operating officer of the business, any senior executive or any member of senior management or the board of directors)

B6 - How do you or your organization keep up with any changes in reporting, record keeping or client identification obligations? Media (newspaper, television, etc.), Seminars, training or conferences, Other web sites , FINTRAC's Web site , Other

B7 - Have you consulted the FINTRAC guidelines?

B8 - If you answered yes to question B7, do you find them useful?

Part C

---

C1 - Do you or your organization have policies and procedures to ensure your reporting, record keeping and client identification requirements are being met?

C2 - Are these policies and procedures in writing? If no, please describe.

C3 - Does your organization cross-reference the names of clients with any anti-terrorism lists of names published by the Canadian government? For more information about these, please refer to the List of Names Subject to the Regulations Establishing a List of Entities made under subsection 83.05(1) of the Criminal Code or the United Nations Suppression of Terrorism Regulations provided by the Office of the Superintendent of Financial Institutions at http://www.osfi-bsif.gc.ca.

Part D

---

D1 - Have you or your organization implemented a process for reviewing your or your organization's compliance policies and procedures to determine their effectiveness?

D2 - Has such a review already been conducted for yourself or your organization?

D3 - If you answered yes to question D2, how often do you or your organization conduct a review? More than once a year, Once a year, Less than once a year

D4 - If you answered yes to question D2, the review was conducted by: (Check all that apply) Compliance officer, Internal Auditor, Consultant, External Auditor, Other

D5 - If you answered yes to question D2, when was the review completed?

D6 - Are the results of the review documented?

Part E

---

E1 - Do you or your organization provide training regarding your reporting, record keeping and client identification obligations?

E2 - If you answered yes to question E1, describe how the training is delivered. Include information about the mode and frequency of delivery as well as a general description of who is required to take the training. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer E2.

Mode of training: In a classroom with trainer/Seminar, Self-directed, Computer-based, Other
Frequency of training: Yearly, More often than yearly (e.g., seasonally, quarterly, etc.) , When new staff is hired , In special circumstances, Other
Who receives the training: All Staff, Brokers / Nominees / Managers, Sales Representatives, Other
Type of material: Handouts, Test, Presentation or group discussion, Other