IN THE MATTER OF the Insurance Act, R.S.O. 1990, c.I.8, as amended (the “Act”), in particular sections 392.4, 407.1, 441.2 and 441.3;

AND IN THE MATTER OF Alessandra Giannini

AND IN THE MATTER OF Inparanee Kanagasabey

AND IN THE MATTER OF AGJR Enterprise Inc.

AND IN THE MATTER OF Arthur G&B Enterprise Inc.

NOTICE OF PROPOSAL TO REFUSE TO RENEW LICENCE AND TO IMPOSE ADMINISTRATIVE PENALTIES

TO:Alessandra Giannini

AND TO:Inparanee Kanagasabey

AND TO:AGJR Enterprise Inc.
410 Chrislea Road, Unit 12
Woodbridge, ON L4L 8B5

AND TO: Arthur G&B Enterprise Inc.
173 Saddle Tree Crescent
Woodbridge, ON L4L 4R6

TAKE NOTICE THAT pursuant to section 441.3 of the Act, and by delegated authority from the Chief Executive Officer of the Financial Services Regulatory Authority of Ontario (the “Chief Executive Officer”), the Director, Litigation and Enforcement, (the “Director”) is proposing to impose three (3) administrative penalties of $100,000 each in the total amount of $300,000 on Alessandra Giannini for contravening section 17(c) of Ontario Regulation 347/04 by making false or misleading statements or representations in the solicitation or registration of insurance and for contravening section 439 of the Act by engaging in an unfair or deceptive act or practice as prescribed under section 8 of Authority Rule 2020-002 (Unfair or Deceptive Acts or Practices)(the “UDAP Rule”).

TAKE NOTICE THAT pursuant to section 441.3 of the Act, and by delegated authority of the Chief Executive Officer, the Director is proposing to impose three (3) administrative penalties of $100,000 each in the total amount of $300,000 on Inparanee Kanagasabey for contravening section 17(c) of Ontario Regulation 347/04 by making false or misleading statements or representations in the solicitation or registration of insurance and for contravening section 439 of the Act by engaging in an unfair or deceptive act or practice as prescribed under section 8 of the UDAP Rule.

TAKE NOTICE THATpursuant to section 441.3 of the Act, and by delegated authority of the Chief Executive Officer, the Director is proposing to impose three (3) administrative penalties of $200,000 each in the total amount of $600,000 on AGJR Enterprise Inc. for contravening section 17(c) of Ontario Regulation 347/04 by making false or misleading statements or representations in the solicitation or registration of insurance and for contravening section 439 of the Act by engaging in an unfair or deceptive act or practice as prescribed under section 8 of the UDAP Rule.

TAKE NOTICE THAT pursuant to section 441.3 of the Act, and by delegated authority of the Chief Executive Officer, the Director is proposing to impose three (3) administrative penalties of $200,000 each in the total amount of $600,000 on Arthur G&B Enterprise Inc. for contravening section 17(c) of Ontario Regulation 347/04 by making false or misleading statements or representations in the solicitation or registration of insurance and for contravening section 439 of the Act by engaging in an unfair or deceptive act or practice as prescribed under section 8 of the UDAP Rule.

TAKE NOTICE THAT pursuant to sections 392.4 and 407.1 of the Act, and by delegated authority from the Chief Executive Officer, the Director is proposing to refuse to renew the life insurance and accident & sickness insurance agent licence issued to Inparanee Kanagasabey.

Details of these contraventions and reasons for this proposal are described below. This Notice of Proposal includes allegations that may be considered at a hearing.

SI VOUS DÉSIREZ RECEVOIR CET AVIS EN FRANÇAIS, veuillez nous envoyer votre demande par courriel immédiatement à: contactcentre@fsrao.ca

YOU ARE ENTITLED TO A HEARING BY THE FINANCIAL SERVICES TRIBUNAL (THE “TRIBUNAL”) PURSUANT TO SECTIONS 407.1(2), 407.1(3), 441.3(2) AND 441.3(5)" OF THE ACT. A hearing by the Tribunal about this Notice of Proposal may be requested by completing the enclosed Request for Hearing Form (Form 1) and delivering it to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you. The Request for Hearing Form (Form 1) must be mailed, delivered, faxed, or emailed to:

Address:
Financial Services Tribunal
25 Sheppard Avenue West, 7^th Floor
Toronto, Ontario
M2N 6S6

Attention: Registrar

Fax: 416-226-7750

Email: contact@fstontario.ca

For additional copies of the Request for Hearing Form (Form 1), visit the Tribunal's website at www.fstontario.ca

TAKE NOTICE THAT if you do not deliver a written request for a hearing to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you, orders will be issued as described in this Notice of Proposal. TAKE FURTHER NOTICE of the payment requirements in section 5 of Ontario Regulation 408/12, which state that the penalized person or entity shall pay the penalty no later than thirty (30) days after the person or entity is given notice of the order imposing the penalty, after the matter is finally determined if a hearing is requested or such longer time as may be specified in the order.

The hearing before the Tribunal will proceed in accordance with the Rules of Practice and Procedure for Proceedings before the Financial Services Tribunal ("Rules") made under the authority of the Statutory Powers Procedure Act, R.S.O. 1990, c. S.22, as amended. The Rules are available at the website of the Tribunal: www.fstontario.ca. Alternatively, a copy can be obtained by telephoning the Registrar of the Tribunal at 416-590-7294, or toll free at 1-800-668-0128 extension 7294.

At a hearing, your character, conduct and/or competence may be in issue. You may be furnished with further and/or other particulars, including further or other grounds, to support this proposal.

REASONS FOR PROPOSAL

I. INTRODUCTION

1. Between 2019 and 2023 (the “Relevant Period”) Alessandra Giannini (“Giannini”) and Inparanee Kanagasabey (“Kanagasabey”) made false statements in approximately 2,000 life insurance policies submitted to Specialty Life Insurance (“SLI”) to support an extensive scheme which generated over $67,000,000 in commissions and bonuses.
2. These are the reasons of the Director to impose administrative penalties in the total amount of $300,000 on Giannini, and $300,000 on Kanagasabey for their roles in this fraudulent scheme, as well as $600,000 on AGJR Enterprise Inc. (“AGJR”) and $600,000 on Arthur G&B Enterprise Inc. (“Arthur G&B”), their respective corporate agencies, and to refuse to renew Kanagasabey’s licence.

II. BACKGROUND

3. Giannini was licensed as a life insurance and accident & sickness insurance agent (licence #00060425). Her licence expired on December 23, 2024. During the Relevant Period, she was the owner and sole director of AGJR, formerly a corporate insurance agency (licence #37166M). AGJR’s licence expired on April 15, 2025.
4. Kanagasabey was licensed as a life insurance and accident & sickness insurance agent (licence #06090746). Her licence expired on June 6, 2024. Kanagasabey applied to renew her licence on April 9, 2024. During the Relevant Period, Kanagasabey was the owner and sole director of Arthur G&B, formerly a corporate insurance agency (licence #38050M). Arthur G&B’s licence expired on June 8, 2025.
5. Kanagasabey was also employed by AGJR in the role of Chief Compliance Officer during the Relevant Period.
6. Giannini and Kanagasabey used AGJR and Arthur G&B, respectively, to submit insurance policy applications to SLI. SLI is licensed as a corporate agent, licence number 35751M. SLI was authorized to provide insurance underwritten by Chubb Life Insurance Company of Canada and Humania Assurance Inc. The applications were either submitted directly to SLI or through a managing general agency (“MGA”) known as Global Insurance Solutions Inc. (“GIS”). Giannini and Kanagasabey acted as insurance agents and advisors for GIS.

III. FACTS

A. False Statements

7. On December 15, 2023, FSRA received a Life Agent Misconduct Report (“LAMR”) from GIS, regarding Giannini. The LAMR alleged misrepresentation to the company and noted that Giannini was under investigation by SLI.
8. On January 8, 2024, FSRA received two Life Agent Reporting Forms (“LARF”) from SLI, regarding both Giannini and Kanagasabey. Both LARFs allege forgery, fraud, licensing violations, misrepresentation to company, and lack of trustworthiness. During an audit by SLI, Giannini and Kanagasabey confessed to the activity.
9. On January 8, 2024, Giannini and Kanagasabey’s contracts were terminated by SLI.
10. During the Relevant Period, Giannini and Kanagasabey submitted insurance applications to SLI for individuals who did not exist or otherwise contained false and misleading information.
11. Giannini and Kanagasabey submitted approximately 2,000 insurance applications to SLI, individually and through their corporate agent licences. In many of those applications, Giannini and Kanagasabey misrepresented:
    1. The insureds’ addresses;
    2. The insureds’ information, including identity and health information; and
    3. Payor information, including bank accounts.
12. The address listed on nearly half of the policies was the AGJR office address. These addresses were used to avoid detection by preventing mail sent to insureds from being returned due to invalid addresses.
13. In many of the insurance applications, Giannini and Kanagasabey specifically represented to SLI that they verified the details in the applications, including identity and health information with the insureds. This was false since the insureds were not real.
14. Many of the false applications identified payors who were different from the insureds. Some payors were repeated hundreds of times for insureds with no apparent connection to one another. Bank accounts were also repeated, but not consistently used between payors.
15. As of November 24, 2023, Giannini and Kanagasabey had written 2,114 policies, generating over $67,000,000 in commissions and bonuses.
16. SLI’s policy was to pay commissions and bonuses of upwards of 200% of the premium amount of the policy within 24 hours of receiving the policy application.
17. Giannini and Kanagasabey diverted some of the commissions and bonuses to different bank accounts to pay premiums to SLI to perpetuate the scheme.

B. Giannini Confession to FSRA

18. On August 19, 2025, FSRA investigators interviewed Giannini. During the interview, she admitted to submitting false insurance applications. She described submitting high volumes of life insurance policies using fabricated applicant information.
19. Giannini stated it took only five minutes to create a false policy and that she received commissions and bonuses of up to 200%, resulting in payments of approximately $40,000 per policy.
20. Giannini admitted that she retained at least $20,000,000 of the commissions and bonuses paid, but did not provide any corroborating evidence to support this figure.

C. Kanagasabey Confession to FSRA

21. On August 15, 2025, FSRA investigators interviewed Kanagasabey. During the interview, Kanagasaby stated that her role primarily involved the submission of false life insurance applications to SLI.
22. Kanagasabey admitted that nearly all of the policies she submitted to SLI contained false information, with only policies for family members being authentic. She claimed she had personal financial difficulties which led to her engaging in the scheme with Giannini.
23. Kanagasabey stated she would submit two to three false policies per day, which generated approximately $100,000 in commission and bonus payments within a 24-hour period.

IV. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. False Statements in the Solicitation or Registration of Insurance

24. Section 17(c) of Ontario Regulation 347/04 prohibits a life insurance agent from making a false or misleading statement or representation in the solicitation or registration of insurance.
25. Giannini and Kanagasabey, directly and through AGJR and Arthur G&B, repeatedly made false and misleading statements in insurance registrations by submitting over 2000 insurance applications with false information, including the insureds’ addresses, identities, health, and payor and bank account information.

B. Unfair or Deceptive Acts or Practices

26. Section 439 of the Act prohibits any person from engaging in an unfair or deceptive act or practice (“UDAP”).
27. Section 438 of the Act defines a UDAP as any activity or failure to act that is prescribed by the Authority rules as an unfair or deceptive act or practice.
28. The UDAP Rule first came into force on April 1, 2022, replacing Ontario Regulation 7/00. Since the UDAP Rule came into force, Giannini and Kanagasabey submitted 1,325 false policies, directly and through AGJR and Arthur G&B.
29. Under section 2(1) of the UDAP Rule, a UDAP is prescribed as conduct, including inaction or omission, which results in, or could reasonably be expected to result in the outcomes, events or circumstances set out in sections 3 through 12 of the UDAP Rule.
30. Section 8(1) of the UDAP Rule specifies that it is a UDAP where conduct causes a person to receive information that a reasonable recipient would consider inappropriate, inaccurate or misleading, respecting the terms of any contract of insurance issued or to be issued.
31. Giannini and Kanagasabey, directly and through AGJR and Arthur G&B, provided SLI with false and misleading information about the terms of 1,325 insurance contracts following the coming into force of the UDAP Rule. Among other things, the insured names, health information, and addresses were false. In nearly all instances, Giannini and Kanagasabey misled SLI as to the existence of a life to insure.

V. GROUNDS TO REFUSE TO RENEW LICENCE

32. Section 392.4(1) of the Act states that the Chief Executive Officer shall issue a licence to act as an insurance agent in Ontario to an applicant who applies in accordance with section 392.3 of the Act and who satisfies the prescribed requirements for the licence unless the Chief Executive Officer believes, on reasonable grounds, that the applicant is not suitable to be licenced having regard to such circumstances as may be prescribed and such other matters as the Chief Executive Officer considers appropriate.
33. Section 4 of Ontario Regulation 347/04, subsections (a) and (i) respectively, provides that an applicant for a licence shall be granted a licence if the Chief Executive Officer is satisfied that the applicant is of good character and reputation, and otherwise suitable to receive a licence.
34. Section 7(4) of Ontario Regulation 347/04 permits the Chief Executive Officer to refuse renewal of an insurance agent licence on any grounds for which a licence may be suspended or revoked.
35. Section 8 of Ontario Regulation 347/04 permits the Chief Executive Officer to suspend or revoke a licence on any grounds on which an application can be refused or if it appears to the Chief Executive Officer that the licensee has:
    1. violated any provision of the licence in the licensee’s operations as an agent;
    2. made a material misstatement or omission in the application for the licence;
    3. been guilty of a fraudulent act or practice; or
    4. demonstrated incompetence or untrustworthiness to transact the insurance agency business for which the licence has been granted.
36. FSRA must assess suitability keeping in mind that the purpose of licensing is to ensure that consumers receive competent and ethical insurance brokering services from those licensed to participate in the industry. When FSRA issues a licence, it is considered a public endorsement that the licensee can serve as a trusted advisor to their clients who often rely on their insurance agents when making important financial decisions that can have a significant impact on their lives and well-being.
37. The Director believes, on reasonable grounds, that Kanagasabey is not suitable and is not of good character or reputation to be licensed under the Act. The repeated misconduct clearly demonstrates untrustworthiness to transact business as an insurance agent.
38. The Director is satisfied that a sanction less than refusal to renew, such as licence conditions, would not reflect the severity of Kanagasabey’s conduct and would not adequately protect consumers. Kanagasabey cannot be trusted to act in accordance with her obligations under the Act or in accordance with any conditions that might be imposed on her licence.

VI. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

39. The Director is satisfied that imposing administrative penalties on Giannini and Kanagasabey under section 441.3(1) of the Act will satisfy one or both of the following purposes under section 441.2(1) of the Act:
    1. To promote compliance with the requirements established under the Act.
    2. To prevent a person from deriving, directly or indirectly, any economic benefit as a result of contravening or failing to comply with a requirement established under this Act.
40. The Director is satisfied that administrative penalties in the total amount of $600,000 each on AGJR and Arthur G&B, and $300,000 each on Giannini and Kanagasabey should be imposed for making false and misleading statements and representations in the solicitation or registration of insurance contrary to section 17(c) of Ontario Regulation 347/04 and engaging in an unfair or deceptive act or practice contrary to section 439 of the Act.
41. Giannini and Kanagasabey, directly and through AGJR and Arthur G&B, submitted policies for individuals who do not exist. By doing so, Giannini and Kanagasabey repeatedly made false and misleading statements with respect to these policies when soliciting and registering insurance in three distinct categories of information, designed to avoid detection of their scheme. The administrative penalties are based on these three categories of information described above, and each category was integral in the overall scheme.
42. In determining the amount of the administrative penalty, the Director has considered the following criteria as required by section 4(2) of Ontario Regulation 408/12:
    1. The degree to which the contravention or failure was intentional, reckless or negligent.
    2. The extent of the harm or potential harm to others resulting from the contravention or failure.
    3. The extent to which the person or entity tried to mitigate any loss or take other remedial action.
    4. The extent to which the person or entity derived or reasonably might have expected to derive, directly or indirectly, any economic benefit from the contravention or failure.
    5. Any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by the person or entity.
43. In respect of the first criterion, the Director is satisfied that Giannini and Kanagasabey intentionally engaged in a pattern of misconduct and providing false and misleading statements and representations to SLI. Giannini and Kanagasabey devised and executed an elaborate scheme to obtain commissions and bonuses through misrepresentations when submitting insurance policies.
44. Giannini and Kanagasabey admitted to being aware that the individuals for whom they were submitting policies did not exist. In addition, their conduct occurred over several years, and included approximately 2,000 insurance applications with false information.
45. In respect of the second criterion, the Director has considered the serious harm that resulted from Giannini and Kanagasabey’s conduct. Giannini and Kanagasabey’s misconduct caused significant harm to both SLI and to public confidence in the regulatory regime established by the Act and its regulations.
46. Through more than 2,000 policy applications containing false names, addresses, and other material details, they induced SLI to pay over $67,000,000 in commissions and bonuses on policies that were entirely fictitious and compromised its operations.
47. Further, Giannini and Kanagasabey’s misconduct undermines the integrity of Ontario’s insurance regulatory regime and erodes public confidence in the life insurance sector. The licensing and regulatory framework under the Act is designed to protect consumers and promote confidence in the sector. By submitting over 2,000 policy applications containing false names, addresses, and other material information, Giannini and Kanagasabey demonstrated a systemic disregard for these protections. This conduct creates the perception that regulatory obligations under the Act can be ignored for personal gain, weakening trust in the industry’s ability to govern itself and comply with statutory requirements.
48. The requirements to provide accurate information in policy applications and to act with honesty and integrity are fundamental to the Act’s purpose. These obligations ensure that insurers, intermediaries, and consumers can rely on the validity of insurance contracts. Giannini and Kanagasabey’s actions not only resulted in significant financial harm through the payment of over $67,000,000 in commissions and bonuses, but also compromised the reliability of the insurance system. When applications containing misrepresentations infiltrate the market, insurers may respond by increasing transaction costs, and limiting access to insurance for legitimate consumers. These are outcomes that harm the public interest.
49. In respect of the third criterion, the Director is not aware of any steps taken by Giannini, Kanagasabey, AGJR or Arthur G&B, to mitigate any loss caused by the contraventions or take any other remedial action.
50. In respect of the fourth criterion, the Director is satisfied that Giannini and Kanagasabey received a significant economic benefit of over $67,000,000 from the commissions and bonuses paid for the false policies, which were paid directly to Giannini and Kanagasabey. They then used these funds to maintain the scheme and for their own financial benefit.
51. In respect of the fifth criterion, the Director is not aware of any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by Giannini or Kanagasabey.
52. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, December 2, 2025

Original signed by

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

Si vous desirez recevoir cet avis en français, veuillez nous envoyer votre demande par courriel immediatement a : contactcentre@fsrao.ca.