Ethics Legal Framework, Privacy & AML question: information record and verify Akira's identity

EthicsLegal Framework, Privacy & AML

Akira, 38, is a software developer in Halifax with two young children. He wants to save for retirement outside his RRSP and buys a non-registered deferred annuity from a life insurer, making deposits of $2,500 a year, which he plans to pay by pre-authorized debit from his chequing account for at least 20 years. Akira asks why the agent needs to see his photo ID. Under the federal anti-money-laundering rules, does the agent's firm have to keep an information record and verify Akira's identity?

A Yes, since $10,000 or more will be paid over time
B No, because identity checks apply only to cash
C No, because no single payment reaches $10,000
D Only if Akira pays the first premium in cash

Show the answer and explanation

Answer: A. Yes, since $10,000 or more will be paid over time

A life insurer or agent must keep an information record, and verify identity, for the sale of a life insurance policy or annuity for which it will receive $10,000 or more over the duration of the policy, regardless of the means of payment. Twenty years of $2,500 deposits is well over $10,000, so the record and verification are required. (Some products are carved out by s. 154(2), such as exempt life policies, registered plans and annuities bought with pension transfers; a non-registered deferred annuity is not.) Source: Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, SOR/2002-184 (current to 21 Sep 2026; as at 12 Oct 2026), ss. 22(1)(a), 92 and 154(2).

Common mistake

Looking only at the size of a single payment.

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Original study material mapped to the public CISRO curriculum; not a real test question.Not affiliated with CISRO, CCIR or any provincial insurance regulator. Verify figures and rules against current guidance before relying on them.