The Insurance Council of British Columbia has found that Anoulack Soudarack (licence no. LIC-197939C144970R1), a life and accident and sickness insurance agent licensed since March 20, 2015, operated for years without the professional liability protection his licence required, while repeatedly declaring on renewal forms that coverage was in place.

The decision, rendered on June 16, 2026, documents a pattern of regulatory non-compliance spanning multiple licence periods and touching on some of the most fundamental obligations a licensee carries: errors and omissions (E&O) insurance, continuing education (CE), and candour with the regulator.

Years without required E&O coverage

The respondent held two concurrent authorizations to represent (ART): an Agency ATR and an unaffiliated ATR. His E&O coverage was provided through the affiliated agency, but he was unaware that his unaffiliated ATR required separate coverage entirely. From November 2019, through April 2024 — more than four years — he operated under that unaffiliated ATR without the required E&O insurance. In December 2019, the agency began holding his Agency ATR; it issued a termination letter in April 2024, confirming that his E&O coverage had ended with his departure.

Despite receiving that written notice, the respondent did not promptly obtain replacement coverage and did not notify Council within five business days as required under Council Rule 7(11)(c). The gap in coverage continued until July 2024. In his May 2024 licence renewal, he declared that he had E&O coverage; a statement he made knowing his coverage had ended.

Continuing education shortfall spans four licence periods

Alongside the E&O failures, the respondent accumulated a shortfall of 46.75 CE credits across four licence periods. He believed insurer training events counted toward the CE requirement and that the requirement was 14 credits per period rather than the actual 15. He did not retain documentation of any training he believed he had completed, and insurers confirmed no CE-accredited course records for the audit period. On annual renewal forms for the licence periods in question, he declared that CE requirements had been met.

Investigation raises further compliance concerns

Council's investigation was triggered when it received a list of lapsed E&O policies indicating the respondent's coverage had been cancelled in April 2024, prompting an audit of his E&O policies and CE records. During that investigation, the respondent was unresponsive to Council's investigator on multiple occasions.

At the Review Committee meeting, he admitted he was unsure whether his current E&O coverage was in place and stated he intended to "cram" CE credits if still deficient. His approach to CE requirements raised further questions: he appeared to have completed the third module of a three-part CE course before completing the first and second modules.

Council flagged the possibility that the respondent may still be providing informal advice to his community while unaffiliated and without E&O coverage; a risk the regulator took seriously.

Insurers contracting through the unaffiliated ATR confirmed no knowledge of the respondent engaging in insurance-related activities in that capacity, and no evidence of client harm was identified.

Council distinguishes between the two coverage lapses

When weighing the sanction, Council drew a clear line between the two E&O lapses. The first period, running from November 2019 to April 2024, was treated as an honest mistake: the respondent genuinely did not understand that his unaffiliated ATR carried a separate E&O obligation. The second, from April to July 2024, was treated more seriously because the respondent had received a termination letter that expressly confirmed his coverage had ended yet did not act.

For the CE breaches, Council applied a $1,000 fine per licence period, above the $500 baseline seen in some precedents. It cited the recurring nature of the failures and the respondent's inability to provide a reasonable explanation. Ignorance of regulatory requirements, it noted, does not negate the breaches; the respondent's subjective belief in compliance was treated as aggravating rather than mitigating, given the false declarations made on renewal forms.

Completing the outstanding CE credits after notification was acknowledged as a mitigating factor but did not negate the underlying shortfall of 46.75 credits. Council described the overall conduct as demonstrating "flagrant disregard for the laws governing the Licensee's conduct," while also noting that each matter is decided on its own facts and merits.

Fines total $5,500, with mandatory training ordered

The sanctions imposed address each area of non-compliance:

  • First E&O lapse: fine of $500, with completion of required courses as a condition of future licensing. The total fines imposed amount to $5,500.
  • Second E&O lapse and failure to notify Council: fine of $1,000.
  • CE credit shortfall across four licence periods: fines of $1,000 per licence period ($4,000 total); required to complete the Council Rules Course for Life and/or Accident & Sickness Agents, the Value of Errors and Omissions Insurance course (Advocis), the Selecting the Right E&O Insurance course (Advocis), and the Continuing Education Requirements & Guidelines Course, all within 90 days of Council's order. Failure to pay the fine and investigation costs and complete the courses within 90 days results in automatic suspension and prohibition from completing the 2028 annual licence renewal.
  • False declarations on annual renewal forms regarding CE completion and E&O coverage, including the May 2024 declaration made after receipt of the termination letter.
  • Failure to respond to Council's multiple inquiries during the investigation.

The respondent was also ordered to pay investigation costs of $1,350. The BC Financial Services Authority has a right of appeal to the Financial Services Tribunal within 30 days of Council's decision taking effect.