Canadian guidance on prescribed methods and timing for verifying the identity of clients and associated persons.
TL;DR:
- Canadian guidance on prescribed methods and timing for verifying the identity of clients and associated persons.
- Use permitted verification methods, establish identity within required timing and keep evidence.
- Retain verification records and support required FINTRAC reports.
Summary
Canadian guidance on prescribed methods and timing for verifying the identity of clients and associated persons. Its scope covers client onboarding, transactions, beneficial owners and third parties.
The main requirements are to use permitted verification methods, establish identity within required timing and keep evidence.
Customer due diligence builds a reliable picture of the person or organisation receiving a financial service. Collecting a name is different from verifying identity, and identifying a company's registered owner is different from understanding its ultimate beneficial owners or controllers. The purpose and expected use of the relationship provide context for assessing later transactions.
Risk-based treatment changes the depth and frequency of the work. Higher-risk circumstances can require additional information or enhanced review, while any simplified approach remains subject to the conditions of the governing framework. Customer information also changes over time: ownership, representatives, business activity and expected payment patterns can all affect the original assessment.
The operational outcome is a documented relationship between identity evidence, the risk decision and ongoing monitoring. Onboarding should feed the transaction-review process, and unusual activity should feed back into the customer assessment. Due diligence is therefore an ongoing information and decision-making process, rather than a one-time collection of documents or a name-screening result.
The instrument also addresses reporting and evidence: retain verification records and support required FINTRAC reports.
Keywords
- FINTRAC Identity Verification Requirements
- FINTRAC ID
- Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
- FINTRAC Identity Verification Requirements summary
- FINTRAC Identity Verification Requirements compliance
- Canada payment regulation
- Canada financial regulation
- Financial Transactions and Reports Analysis Centre of Canada regulation
- customer due diligence
- KYC and customer due diligence