Client Due Diligence

Verification of Identity

Verifying the identity of a client is one of the most important elements of the anti-money laundering/anti-terrorist financing controls. AML/ATF legislation requires Sun Life Financial to obtain identification information for all clients and to take appropriate steps to verify the identity of its clients. Bermuda International Operations' policies and procedures are designed to obtain the necessary client information and, where required, documentation.

Verification of identity is required for all new clients and for some in-force clients, as well as for some third parties. A client may be an individual, corporation, trust, or other type of entity ("Verification Subject").

A "verification subject" includes:

• Owner/Participant
• Payor
• Payee
• Beneficial Owner(s) including:
  • Individuals or Entities with 10% or more of direct or indirect ownership or control of a legal entity identified as Owner of the contract and/or beneficiary(ies) at the time of a claim.
  • Beneficiaries of trusts as described below
• Third Parties (when disclosed) who control or give direction to the Owner/Participant
• Individual or Corporate Trustees or Directors

Identity Requirements for INDIVIDUALS

• Description of source of wealth in addition to accountholder name, number, and financial institution where funds originated if individual is a Payor.
• Copy of original unexpired identification document used to verify identity and recording of original unexpired passport or government issued identity document with unique number and country of issue.

A copy of an identity document will be considered acceptable, if, at a minimum, it is issued by a governmental entity, such as a passport or national identity card, contains a unique identification number and is not expired.  The identity document must also include a photograph, may include a signature, and must be legible.  The copy of the identity document may also include an attestation from the Financial Representative that it is a true and accurate copy of the original.  Where country of citizenship and residency differ, an acceptable identity document from each country is required.

Identity Requirements for COMPANIES

• Description of source of wealth in addition to accountholder name, number, and financial institution where funds originated if the Corporation is a Payor.
• Name, occupation, date & place of birth and identification information of all Directors with copies of acceptable identity documents.
• Ownership or controlling Interest (underlying beneficial owner):
  • Name, date & place of birth, residence, business, occupation and copies of acceptable identity documents of Individuals with 10% or more direct or indirect ownership or control of the Company's shares,
  • If 10% or greater ownership is by another corporation or entity, the same information must be obtained for that entity.
• Authenticated copy of the Certificate of Incorporation
• Authenticated copy of the Certificate of Incumbency OR Certificate of Good Standing (considered current if dates within 12 months of the Application date)
• Authorized signatory list with names, titles, specimen signatures, and effective date if the Corporation is the contract Owner/Participant.

Identity Requirements for TRUSTS

• Description of source of wealth in addition to accountholder name, number, and financial institution where funds originated if the Trust is a Payor.
• Ownership or Controlling Interest:
  • Name, date & place of birth, residence, business, occupation and copies of acceptable identity documents of Individuals who are the Settlor and known beneficiaries with a vested interest in 10% or more of the of the Trust property.
  • Name, occupation, date & place of birth and copies of acceptable identity documents of Individual Trustees.
• Authorized signatory list with names, titles, specimen signatures, and effective date if the Trust is the contract Owner/Participant.

Identity Requirements for PARTNERSHIPS

• Description of source of wealth in addition to accountholder name, number, and financial institution where funds originated if the Partnership is a Payor.
• Ownership or Controlling Interest:
  • Name, date & place of birth, residence, business, occupation and copies of acceptable identity documents of Controlling Individual Partners holding 10% or more direct or indirect ownership or control of the Partnership.
• Date and Place of establishment of Partnership
• Authenticated copy of the Partnership Agreement (for equivalent)
• Authorized signatory list with names, titles, specimen signatures, and effective date if the Partnership is the contract Owner/Participant.

Identity Requirements for FOUNDATIONS

• Description of source of wealth in addition to accountholder name, number, and financial institution where funds originated if the Foundation is a Payor.
• Ownership or Controlling Interest:
  • Name, date & place of birth, residence, business, occupation and copies of acceptable identity documents of Individuals holding 10% or more direct or indirect ownership or control of the Foundation.
• Authenticated copy of a confirmation by a public registry that the foundation has been registered
• If a non-profit organization, determine if it solicits charitable donations from the public
• Authorized signatory list with names, titles, specimen signatures, and effective date if the Foundation is the contract Owner/Participant.
• Letter of Introduction from the bank where the funds for payment are on deposit attesting that the Foundation and its Directors are known to the bank.

Identity Requirements for BENEFICIARIES

• Current identification information must be obtained at time of claim in accordance with the above guidelines.
• When a Trust is the claimant, current identification information on the beneficiary(ies) of the Trust is required.
• When a corporation/partnership/foundation or other entity is the claimant, current identification information on the underlying beneficial owners who own or control 10% or more of the entity required.
• All claimants will be screened against applicable watchlists prior to disbursement of funds.

Source of Wealth and Source of Funds

The Bermuda Monetary Authority, our primary regulator, requires that we obtain source of wealth documentation for all accounts. We have prepared and published the Guide to Client Due Diligence Documentation Requirements to assist you and your clients in understanding acceptable forms of documents.

Restricted Countries (AML/ATF)

Sun Life Financial has placed restrictions on the following countries due to risk factors including applicable government sanctions. Please contact us for complete information.

Prohibited Countries

Citizens, residents, or individuals with nexus to these countries are required to provide a completed Restricted Country Questionnaire.

Sanctioned Countries

Note: These lists are subject to change without notice. Contact us for current information with respect to a specific country.

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