FINTRAC's Identity Verification Requirements explain the methods and timing for identifying clients and associated persons in Canada. They connect the verification decision with evidence and reporting, helping payment providers distinguish collecting identity data from verifying it.
TL;DR:
- Permitted identity methods each have distinct evidence, matching and record requirements.
- Entity verification uses appropriate existence checks; timing follows sector-specific rules.
- Agents, vendors and reliance arrangements do not remove the reporting entity's responsibility.
Summary
Methods for verifying customer identity
FINTRAC's identity-verification guidance explains how reporting entities can verify the identity of persons and entities under Canada's anti-money-laundering legislation. It distinguishes the methods used to establish identity from the separate question of when a particular sector must perform the check. A payment provider must therefore consider both its sector-specific trigger and the requirements of the chosen verification method.
Five routes for identifying a person
The guidance describes government-issued photo identification, the credit-file method, the dual-process method, the affiliate or member method and the reliance method. Each has its own conditions. For example, the credit-file method requires a valid and current Canadian file meeting the stated history and matching requirements; it is not satisfied simply by accepting a credit report supplied by the customer. A method's name alone is therefore insufficient evidence that its conditions were met.
Independent information and entity checks
The dual-process method combines information from two different reliable sources to confirm the required categories of identifying information. FINTRAC explains what makes a source reliable and distinguishes the originator of information from an aggregator. The guidance also covers verification of entities through confirmation of existence, which is a different exercise from identifying the individual using an account or acting for a company.
Records and responsibility for the result
Reporting entities must keep the records required for the method used and describe their procedures in the compliance programme. The guidance addresses agents, mandataries and reliance arrangements, but using another party does not remove the reporting entity's responsibility to ensure that the conditions are met. For payments, the document supports defensible onboarding and verification processes; it does not certify a vendor or establish one universal check for every customer and transaction.
Keywords
- FINTRAC
- identity verification
- photo identification
- credit files
- dual process
- entity checks
- reliance arrangements
- reliable sources
- verification records
- agent responsibility