I noticed two significant changes this time around in the process:
- The Freezing Assets of Corrupt Foreign Officials Act (S.C. 2011, c. 10), from March 2011, now requires financial institutions to determine if any people they deal with may be associated with "politically exposed foreign persons" within the meaning of the Act. This was noted as part of the questionnaire in the mortgage application.
- The money-laundering rules relating to suspicious transactions and terrorist property have now tightened up to the degree that financial institutions have to confirm the source of funds used to make a deposit under the real estate agreement of purchase and sale. As my wife was converting some USD funds over for this, she had to present copies of her account statements to prove that the funds were legitimate.
This is a significant improvement to previous practice, and is to be welcomed. I have always been above-board in documenting how funds flow for key transactions, and have been complimented on the transparency of my reporting. It's nice to know others are catching up.