Methods to identify individuals and confirm the existence of entities

How to identify individuals and confirm the existence of entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations. This guidance applies to all reporting entity sectors.

June 2017

**Note: The transition period to adopt the new methods to verify the identity of individuals has been extended until January 23, 2018. Over this transition period, reporting entities can rely on either the new client identification methods outlined in this guideline or the old methods, previously found in Guideline 6, now located in Annex 1 of this Guidance.

Methods to identify individuals and confirm the existence of entities

The Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) specify when you must identify a client and how you must do this. The point at which you identify a client will vary depending on the activity or transaction your client is carrying out.

The methods used to identify individuals and confirm the existence of entities is the same for every sector and this guidance presents the methods that are deemed acceptable. This guidance also clarifies when you can rely on an agent or mandatary, or another entity to identify your clients. Identifying a client requires viewing certain information to verify a client’s identity and ensuring that this information matches what is known about that client.

You do not have to re-identify a client if you previously did so using the methods specified in the Regulations that were in place at the time, and you kept the relevant records, so long as you have no doubts about the information used.

The tables below summarize the client identification methods for individuals and entities, and outline your related recordkeeping obligations.

Table 1: Summary of methods to identify an individual
How to identify an individual directly

Identification method Documents or information to review Identification details that must match Recordkeeping obligations
Photo identification Photo identification issued by government Name and photograph
  • Client identification information
  • Type of document
  • Document number
  • Issuing jurisdiction and country
  • Expiry date
  • Date of verification
Credit file Canadian credit file in existence for at least three years Name, address and date of birth
  • Client identification information
  • Source of credit file
  • Reference number
  • Date of verification
Dual process Two original, valid and current  documents or information from independent and reliable sources Name, address and date of birth
  • Client identification information
  • The name of the two different sources used to identify your client
  • The type of information
  • Account or reference number
  • Date of verification

Table 2: Summary of who can identify an individual on your behalf
How to identify an individual’s identity by using an agent, mandatary or entity

An individual can be identified by your: Recordkeeping obligations
Domestic or foreign affiliate
  • Client identification information
  • Name of the entity that identified your client
  • The identification method used
  • Information gathered according to the method used
  • Date of verification
Financial services cooperative or credit union central
Agent or mandatary
  • Client identification information
  • Name of the entity that identified your client
  • Written agreement with agent
  • The identification method used
  • Information gathered according to the method used
  • Date of verification
  • Date you referred to their verification of your client

Table 3: Summary of methods to confirm the existence of entities

Entities can be corporations, trusts, partnerships, funds, and unincorporated associations or organizations. When you have to confirm the existence of a corporation, you also have to verify its name and address, and the names of the corporation’s directors.

Confirming the existence of an entity that is a corporation
Documents to review Identification details that must match Record keeping obligations

Documents that you can rely on to confirm the existence of a corporation:

  • The corporation’s certificate of corporate status;
  • A record that has to be filed annually under provincial securities legislation;
  • Any other record that confirms the corporation's existence, such as:
    • the corporation’s published annual report signed by an independent audit firm; or
    • a letter or a notice of assessment for the corporation from a municipal, provincial, territorial or federal government.

Name and address of the corporation

Names of the Directors

If you referred to an electronic document you must record:

  • The corporation’s registration number;
  • The type of document referred to; and
  • The source of the electronic version of the document.

If you referred to a paper copy of a document you must keep the paper document, or a copy of it.

Confirming the existence of an entity other than a corporation
Documents to review Identification details that must match Record keeping obligations

Documents that you can rely on to confirm the existence of an entity other than a corporation:

  • A partnership agreement;
  • Articles of association; or
  • Any other similar record that confirms the entity's existence.

Name and address of the entity.

If you referred to an electronic record you must record:

  • The entity’s registration number;
  • The type of record referred to; and
  • The source of the electronic version of the record.

If you referred to a paper document, you must keep the paper document, or a copy of it.

Single process methods to identify individuals

You can identify an individual using one of the following single process methods:

  1. The government-issued photo identification method;
  2. The credit file method.

1. Government-issued photo identification method

How to use a photo identification document to identify an individual

You can rely on valid, current and original photo identification issued by a federal, provincial or territorial government to identify an individual. You may accept a foreign issued photo identification document if it is equivalent to a Canadian issued photo identification document listed in this guideline. Photo identification documents issued by any municipal government, Canadian or foreign, are not acceptable.

You must view the original document while in the presence of the individual in order to compare them with their photo. The photo identification document must:

  1. indicate the individual’s name;
  2. have a photo of the individual;
  3. have a unique identifier number.

It is not acceptable to view photo identification online, through a video conference or through any virtual type of application; nor can you accept a copy or a digitally scanned image of the photo identification.

What information needs to be recorded when using the photo identification method?

If you are using this method, you must record: 

  1. The individual’s name;
  2. The type of card or document used (for example, driver’s license, B.C. Services Card);
  3. The unique identifier number of the document or card;
  4. The issuing jurisdiction and country of the document;
  5. The expiry date of the document or card, if available (if the information appears on the document or card, you must record it);
  6. The date on which you verified the information.

Examples of acceptable photo identification documents

The following list provides examples of acceptable government-issued photo identification documents from federal, provincial or territorial authorities. This is not an exhaustive list.

Table 4: Examples of acceptable photo identification documents
Type of card or document Issuing jurisdiction and country
Canadian passport Canada
Permanent resident card Canada
Citizenship card (issued prior to 2012) Canada
Secure Certificate of Indian Status Canada
Driver's licences
British Columbia Driver’s Licence British Columbia, Canada
Alberta Driver’s Licence Alberta, Canada
Saskatchewan Driver’s Licence Saskatchewan, Canada
Manitoba Driver’s Licence Manitoba, Canada
Ontario Driver’s Licence Ontario, Canada
Québec Driver’s Licence Québec, Canada
New Brunswick Driver’s Licence New Brunswick, Canada
Nova Scotia Driver’s Licence Nova Scotia, Canada
Prince Edward Island Driver’s Licence Prince Edward Island, Canada
Newfoundland and Labrador Driver’s  Licence Newfoundland and Labrador, Canada
Yukon Driver’s Licence Yukon, Canada
Northwest Territories Driver’s Licence Northwest Territories, Canada
Nunavut  Driver’s Licence Nunavut, Canada
The DND 404 Driver’s Licence The Department of National Defence, Canada
Provincial services cards
British Columbia Services Card British Columbia, Canada
Provincial or territorial identity cards
British Columbia Enhanced ID British Columbia, Canada
Alberta Photo Identification Card Alberta, Canada
Saskatchewan Non-driver photo ID Saskatchewan, Canada
Manitoba Enhanced Identification Card Manitoba, Canada
Ontario Photo Card Ontario, Canada
New Brunswick Photo ID Card New Brunswick, Canada
Nova Scotia Identification Card Nova Scotia, Canada
Prince Edward Island Voluntary ID Prince Edward Island, Canada
Newfoundland and Labrador Photo Identification Card Newfoundland and Labrador, Canada
Yukon General Identification Card Yukon, Canada
Northwest Territories General Identification Card Northwest Territories, Canada
Nunavut General Identification Card Nunavut, Canada
Type of card or international document
United States passport United States
France driver’s licence France
Australian driver’s licence New South Wales, Australia

Note: You cannot use a provincial health card for identification purposes where it is prohibited by provincial legislation.

2. Credit file method

How to use the credit file method to identify an individual

You can identify an individual by referring to a Canadian credit file that has been in existence for at least three years. To be acceptable, the credit file details must match the name, date of birth and address provided by the individual. If any of the information does not match, you will need to use another method to verify the individual’s identity.

Complete credit files provide ratings on individuals to assess their ability to repay loans; however, it is possible to request a credit file to confirm an individual’s identifying information that does not include a credit assessment. You do not need a credit assessment to identify an individual. Equifax Canada and TransUnion Canada are Canadian credit bureaus that provide credit file information for identification purposes.

An individual cannot provide you with a copy of their credit file. You must obtain the information directly from a Canadian credit bureau. It is acceptable, however, to use an automated system to match the individual’s information with the credit file information. You may also rely on a third party vendor that can provide you with an original and valid Canadian credit file. A third party vendor is an entity that is authorized by a Canadian credit bureau to provide Canadian credit information.

To rely on a credit file search, you must conduct the search at the time you identify the individual’s identity. For example, a previous credit file would not be acceptable. To be acceptable as a single source, the credit file must:

  1. match the name, address and date of birth that the individual provided;
  2. be from Canada; foreign credit files are not acceptable;
  3. have been in existence for at least three years.

The individual does not need to be physically present at the time you confirm their identity.

What information needs to be recorded when using the credit file method?                                 

If you are using this method, you must record: 

  1. The individual’s name;
  2. The name of the Canadian credit bureau holding the credit file;
  3. The reference number of the credit file;
  4. The date you consulted or searched the credit file.

Dual process method to identify an individual

You can identify an individual using the dual process method. This method involves referring to information from two different and reliable, independent sources. The information may be found in documents from these sources or may be information that these sources are able to provide. Information refers to facts provided or learned about an individual and can come from various places. Whereas a document refers to an official record that is either written, printed or electronic that provides evidence or facts.

If you refer to a document, you must view the original, valid and current document. Original documents do not include those that have been photocopied, faxed or digitally scanned. If you refer to information, it must be valid and current. Information found through social media is not acceptable.

The individual does not need to be physically present at the time you confirm their identity.

What is a reliable source?

A reliable source is an originator or issuer of information that you trust to verify the identity of the client. When you are relying on a source to verify an individual’s name and address or an individual’s  name and date of birth, the source must be reliable. To be considered reliable, the source should be well known and considered reputable, and be one that you trust to verify the identity of the individual.

The source providing the information cannot be you, as the reporting entity, or the individual who is being identified; it must be independent. For example, reliable sources can be the federal, provincial, territorial and municipal levels of government, crown corporations, financial entities or utility providers.

What is an acceptable original document?

If you are referring to a document you are using as part of the dual process method, you must ensure that you see the original paper or electronic document and not a copy. The original document is the one that the individual received or obtained from the issuer either through posted mail or electronically. The document must appear to be valid and unaltered in order to be acceptable. If any information has been redacted, it is not acceptable.

For example, an original paper document can be a utility statement mailed to an individual by the utility provider. Whereas an original electronic document is one an individual received through email or by downloading it directly from the issuer’s website.

An individual can email you the original electronic document they received or downloaded, show you the document on their electronic device (for example, a smartphone, tablet, or laptop), print the electronic document received or downloaded from the issuer, or show you in the original format such as .pdf (Adobe) or .xps (Microsoft viewer).

Examples

How to use the dual process method to identify an individual

The dual process method to confirm an individual’s identity requires that you refer to any two of the following:

You must refer to original documents or information from two different, reliable sources to verify an individual’s identity, and all the information must match the information provided by the individual. If you refer to an original document that has an expiry date, it must be current, and if there is no expiry date, it must be a recent version of the document. For example, if an individual provides you with a credit card statement or a Canada Revenue Agency (CRA) notice of assessment, it would need to be the latest one received by the individual.

You cannot rely on information issued by a single source, even if it confirms an account and contains the name, address and date of birth of an individual. You also cannot use the same source for the two categories of information you use to verify the individual’s identity. For example, you can refer to a bank statement that contains the individual’s name and address from Bank A and confirm a deposit account at Bank B. You cannot rely on a CRA document that contains the individual’s name and address and a different CRA document that contains the individual’s name and date of birth, because CRA is the same originating source for both documents.

Table 5 provides examples of information you can rely on to verify an individual’s identity using the dual process method. For example:

  1. You refer to one source to verify an individual’s name and address and a second source to verify their name and date of birth.
  2. You refer to one source to verify an individual’s name and address and a second source to verify their name and confirm a financial account.
  3. You refer to one source to verify an individual’s name and date of birth and a second source to verify their name and confirm a financial account.

Table 5: Examples of reliable sources of information under the dual process method to identify an individual

This is not an exhaustive list. You must always rely on valid and current information, or original, valid and current documents from two independent and reliable sources.

Documents or information to verify name and address

Column A

Documents or information to verify name and date of birth

Column B

Documents or information to verify name and confirm a financial account

Column C

Issued by a Canadian government body

  • Any  card or statement issued by a Canadian government body (federal, provincial, territorial or municipal)
    • Canada Pension Plan (CPP) statement
    • Property tax assessment issued by a municipality
    • Provincially-issued vehicle registration
  • Benefits statement
    • Federal, provincial, territorial, and municipal levels
  • CRA documents:
    • Notice of assessment
    • Requirement to pay notice
    • Installment reminder / receipt
    • GST refund letter
    • Benefits statement

Issued by other Canadian sources

  • Utility bill (for example, electricity, water, telecommunications)
  • Canada 411
  • T4 statement
  • Record of Employment
  • Investment account statements (for example, RRSP, GIC)
  • Canadian credit file that has been in existence for at least 6 months
  • Product from a Canadian credit bureau  (containing two trade lines in existence for at least 6 months)

Issued by a foreign government

  • Travel visa

Issued by a Canadian government body

  • Any  card or statement issued by a Canadian government body (federal, provincial, territorial or municipal)
    • Canada Pension Plan (CPP) statement of contributions
    • Original birth certificate
    • Marriage certificate or government-issued proof of marriage document (long-form which includes date of birth)
    • Divorce documentation
    • A permanent resident card
    • Citizenship certificate
    • Temporary driver’s licence (non-photo)

Issued by other Canadian sources

  • Canadian credit file that has been in existence for at least 6 months
  • Insurance documents (home, auto, life)
  • Product from a Canadian credit bureau (containing two trade lines in existence for at least 6 months)

Confirm that your client has a deposit account, credit card or loan account by means of :

  • Credit card statement
  • Bank statement
  • Loan account statement (for example. mortgage)
  • Cheque that has been processed (cleared, non-sufficient funds) by a financial institution
  • Telephone call, email or letter from the financial entity holding the deposit account, credit card or loan account.
  • Identification product from a Canadian credit bureau (containing two trade lines in existence for at least 6 months)
  • Use of micro-deposits to confirm account

How to rely on the credit file for the dual process method

A Canadian credit file that has been in existence for at least 6 months can be referred to as one source to verify name and address, name and date of birth or name and confirmation of a financial account. A second source from the dual process method, for example a CRA notice of assessment, must be relied on to verify the second category of information. In this instance, the two sources are the credit bureau that provided the credit file and CRA as the source of the notice of assessment. The information from these two sources must match the information provided by the individual.

The reference number for a credit file must be unique to the individual and associated to the credit file, it cannot be a reference number created by you. 

You can also obtain information from a credit bureau if they are acting as an aggregator and compiling original sources, often referred to as tradelines, so long as you are obtaining the identifying information from those tradelines. In this instance, the credit bureau must provide you with two independent, original tradelines as sources that verify the individual’s name and address, name and date of birth or name and confirmation of financial account. Each tradeline is a source, not the credit bureau. 

If the full financial account number is not provided because it was truncated or redacted, it is not acceptable. You must also confirm that the tradeline is not your own, as the reporting entity, and that each tradeline originates from a different source.  

What information needs to be recorded when using the dual process method?

There are specific records you must keep if you are using this method to verify an individual’s identity. You must record:

  1. The individual’s name;
  2. The name of the two different sources that were used to identify the individual;
  3. The type of information (for example, utility statement, bank statement, marriage license, CRA notice of assessment);
  4. The account number associated with the information
    1. If there is no account number, you must record a reference number that is associated with the information;
  5. The date you verified the information.

Who can you rely on to identify an individual on your behalf?

This section explains when you can rely on another entity, agent or mandatary to verify the identity of an individual. You are legally responsible for verifying the identity of your client, even if you rely on another entity, agent or mandatary to do this for you. If you have any concerns about the methods or information used to identify an individual, you should re-verify their identity.

To identify an individual, you can rely on:

Entities, agents or mandataries that identify an individual for you must have used one of the methods described in the Regulations in place at the time, and the information in their records must match the name, address and date of birth that the individual provided.

Domestic and foreign affiliates

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated.

To rely on your affiliate for client identification purposes, they must also meet the definition of a bank, authorized foreign bank, cooperative credit society, savings and credit union, caisse populaire, life insurance company, trust company, loan company, or securities dealer. In other words, your affiliate must be recognized as an entity under paragraph 5(a) to (g) in the PCMLTFA.

Financial services cooperative or credit union central

Financial services cooperatives or credit union centrals act on behalf of a membership composed of financial entities and can provide financial services to that group. A financial services cooperative is a cooperative that is regulated by the Act respecting Financial services cooperatives or the Act Respecting the Mouvement Desjardins.

A credit union central is a central cooperative credit society under the Cooperative Credit Associations Act, or a credit union central or federation of credit unions or caisses populaires regulated by provincial Acts outside of Quebec. You can rely on a member of your financial services cooperative or credit union central to verify the identity of an individual.

For example, Credit Union A has identified an individual and this same individual decides to open an account with Credit Union B. If Credit union A and B are members of the same credit union central, then Credit Union B can rely on the client identification conducted by Credit Union A.

Agent or mandatary

You must have a written agreement or arrangement with an agent or mandatary before you rely on them to verify a client’s identity.

You must obtain all the identification information referred to by the entity, agent or mandatary, and you must be satisfied that the information collected by the entity, agent or mandatary is valid and current, and that the individual was identified using the client identification methods.

What information needs to be recorded if an entity, agent or mandatary identified an individual on your behalf?

Anyone identifying an individual on your behalf must meet the requirements listed under each client identification method in this guideline, and the information must match what the individual provided.

Your records must include:

  1. The full name of the entity, agent or mandatary that identified the individual;
  2. The client identification method that was used;
  3. The information that was gathered by the entity, agent or mandatary to verify the identity of the individual.
  4. The date on which the entity, agent, or mandatary verified the identity of the individual;
  5. The date you referred to the client identification information provided by the entity, agent or mandatary;
  6. If client identification was conducted by an agent or mandatary, you must maintain a copy of the agreement.

What if the agent or mandatary has already identified an individual?

You can rely on client identification information previously collected by an agent or mandatary. For example, if the agent identified the individual’s for another entity, and the information is still current, you can rely on it for your purposes.

If the identifying information that the agent used to verify the individual’s identity has now expired, you can still rely on it, as long as your agreement or arrangement existed with the agent before the information expired. The agent would have to re-identify the individual if the identification information expires before you have an agreement in place with that agent or mandatary.

What if the information does not match the information the client provided?

If the name, address or date of birth in the information you are referring to does not match the information you collected from the individual, then you cannot rely on it for client identification purposes.

How do you identify a child?

If a child is under 12 years of age, you must verify the identity of the parent or guardian and record the parent’s or guardian’s information. You can rely on the information provided by the parent in order to record the child’s identification details.

If a child is between 12 and 15 years of age, you can verify their identity directly using one of the methods outlined in this guideline, as long as you can refer to the required documents or information. If that is not possible, you can rely on one source of information that contains the name and address of the child’s parent or guardian and a second source that contains the child’s name and date of birth. For example, if the child has a passport you can ascertain their identity directly, if not, you could rely on the parent’s driver’s license to verify their common address and the child’s birth certificate to verify the child’s name and date of birth.

Confirming the existence of an entity other than a corporation

An entity can be corporations, trusts, partnerships, funds, and unincorporated associations or organizations.

The existence of an entity can be confirmed by referring to a partnership agreement, articles of association or any other similar record that confirms an entity’s existence. The record you use can be a paper or electronic document that is obtained from a source that is accessible to the public. Although such information may be available verbally (such as by phone), it is not acceptable for these purposes, as you have to refer to a document and keep a record.

How do I confirm the existence of an entity that is a corporation?

In the case of a corporation, in addition to confirming its existence, you also have to determine the corporation's name, address and the names of its directors. It is possible to use the same document to confirm the directors’ information and the corporation’s existence. However, you may need to see the list of the corporation's directors that was submitted with the application for incorporation.  Please refer to FINTRAC’s Know your client guidance for more information.

In the case of a corporation that is a securities dealer, you do not need to determine the name of the corporation's directors.

To confirm the existence of a corporation, as well as its name and address, refer to:

You do not need to verify the names of the directors when you confirm the existence of a corporation that is a securities dealer.

What record do I need to keep when I confirm the existence of an entity or corporation?

In order to confirm the existence of an entity you must refer to a paper document or an electronic version from a source accessible to the public such as a database. Even if you receive the initial information verbally you must refer to paper or electronic document to be able to confirm the existence of the entity. If the information is received from a paper document you must either retain it or keep a copy of it as your record.  

If you refer to an electronic version of a record to confirm the existence of an entity, you must keep a record of the:

For example, you can obtain a corporation's name and address and the names of its directors from a provincial or federal database such as the Corporations Canada database, which is accessible from Innovation, Science and Economic Development Canada website. You may also get this type of information if you subscribe to a corporation searching and registration service.

The use of personal information

The use of personal information in Canadian commercial activities is protected by the Personal Information Protection and Electronic Documents Act (PIPEDA), or by substantially similar provincial legislation. You have to inform individuals concerning the collection of personal information about them. However, you do not have to inform individuals when you include personal information about them in any of the reports that you are required to make to FINTRAC. You can get more information about your responsibilities in this area from the following:

For further information, please contact FINTRAC.

Annex 1

This Annex contains the previous Guideline 6 - Methods to ascertain the identity of individual clients.

The transition phase, where you may rely on the methods described in this Annex, has been extended until January 23, 2018.

As of January 24, 2018, this annex will be removed and you will be required to use the new ‘methods to identify individuals and confirm the existence of entities’ from that day forward.  

Methods to identify individuals and confirm the existence of entities (previously called Guideline 6)

To ascertain the identity of an individual according to the methods in this annex, you can use one of the following: the individual's birth certificate, driver's license, passport, record of landing, permanent resident card or other similar document.

For a document to be acceptable for identification purposes, it must have a unique identifier number. Also, the document must have been issued by a provincial, territorial or federal government. For example, a birth or baptismal certificate issued by a church would not be acceptable for this purpose. Also, an identification card issued by an employer for an employee (that is, an employee identification card) is not acceptable.

The document also has to be a valid one and cannot have expired. For example, an expired driver's license would not be acceptable.

Examples of other documents that can be used to ascertain the identity of a client include a certificate of Indian status or a provincial or territorial identification card issued by any of the following (or their successors):

Valid foreign identification, if equivalent to an acceptable type of Canadian identification document, would also be acceptable for the purposes explained in this annex. For example, a valid foreign passport is acceptable.

When you refer to a document to ascertain the identity of an individual, it has to be an original, not a copy of the document. In cases where it is not possible for you to view the original yourself, you may choose to use an agent or mandatary to verify the original identification document on your behalf. Even if you use an agent or mandatary, you are responsible for making sure the identification requirements are met.

Use of an agent or mandatary

If you use an agent or mandatary to meet your client identification obligations, you have to enter into a written agreement or arrangement with the agent or mandatary outlining what you expect them to do for you. In addition, you have to obtain from the agent or mandatary the customer information that was obtained according to the agreement or arrangement. The agent or mandatary can be any individual or entity, as long as you meet these two conditions regarding written agreement and obtaining customer information.

Your agent or mandatary can ascertain the identity of your client for you using an identification document. In cases where your client is not physically present at the opening of an account, establishment of a trust or conducting of a transaction, your agent or mandatary can also use the options explained below.

Identifying an individual who is not physically present

If you have to identify an individual who is not physically present you must use one of the following two options:

Option 1:  Use of an affiliate or co-member

To ascertain the identity of an individual using this option, you have to first obtain the individual's name, address and date of birth. Then, you have to confirm that one of the following has ascertained the identity of the individual by referring to an original identification document:

To use this option, you have to verify that the individual's name, address and date of birth provided to you correspond with the information kept in the records of that other entity.

In this context, an entity is affiliated with you if you fully own it or it fully owns you, or you are both fully owned by the same entity.

Option 2:  Combination of methods

To ascertain the identity of an individual using this option, you have to use a combination of two of the following methods. In each of the two methods you use, the individual's information has to be consistent with what you have in your records.

The information also has to be consistent from one method to the other. For example, if each of the methods you use has the name, address and date of birth information about the individual, all of it has to agree with what you have in your records.

The methods below may not apply for all clients. For example, the methods would not be available to ascertain the identity of a client outside Canada who is opening an account with you, but has no Canadian credit history, no access to a Canadian guarantor and no deposit account with a financial entity. In this case, ascertaining the identity of the client using an identification document may necessitate the use of an agent or mandatary, as explained above.

Identification product or credit file method

You can use the following methods:

If you are ascertaining the identity of an individual for a credit card account, you can combine the identification product and credit file methods. Otherwise, these methods cannot be combined.

Products for either of these methods are available commercially, such as those used for credit ratings.

Attestation method

Obtain an attestation that an original identification document for the individual has been seen by a commissioner of oaths or a guarantor. The attestation must be on a legible photocopy of the document and include the following information:

In this context, a guarantor has to be an individual engaged in one of the following professions in Canada:

Cleared cheque or deposit account method

You can use the following methods.

If you are ascertaining the identity of an individual for a credit card account, you can combine the cleared cheque and deposit account methods. Otherwise, these methods cannot be combined.

If you use the cleared cheque or deposit account method, the account cannot be one that is exempt from identification requirements as explained in FINTRAC guidance titled “when to identify clients.”

Additional methods available only for credit card accounts

If you have to ascertain the identity of an individual who is not physically present at the opening of a credit card account, you can use either option 1 or option 2 as described above. For option 2, additional methods are available as follows:

Required client identification records

If you have to ascertain the identity of the individual using an identification document, the record has to include the type of document you used to confirm the individual's identity, its reference number and its jurisdiction of issue.

Records required for the identification of clients who were not physically present

If you rely on a method to identify an individual who is not physically present you have to keep the following information according to the methods that was used:

Definitions

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and related regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated. (entité du même groupe)

Branch

A branch is a part of your own business at a distinct location other than your main office. (succursale)

Clarification Request

A clarification request is a method used to communicate with you when we need more information about your registration form. This request is usually sent to you by email. If you do not reply to a clarification request, your registration can be denied or revoked. (demande de precisions)

Compliance officer

The individual you appoint to be responsible for the implementation of your compliance regime. Your compliance officer should have the authority and the resources necessary to discharge his or her responsibilities effectively. Depending on your type of business, your compliance officer should report, on a regular basis, to the board of directors or senior management, or to the owner or chief operator. (agent de conformité)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

  • enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payment for credit card purchases;
  • processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
  • providing other ancillary services to the merchant. (entreprise d’acquisition de cartes de crédit)
Current

A document or information that is up to date (the most recent) and is not expired. (document ou renseignement à jour)

Electronic Funds Transfer (EFT)

An electronic funds transfer (money transfer) means the transmission of instructions for the money transfer of funds to or from Canada. An electronic funds transfer does not include the instructions for the money transfer of funds from one place in Canada to another in Canada. (télévirement)

Entity

Can be a corporation, trust, partnership, fund, or an unincorporated association or organization. (entité)

Financial account

Refers to deposit, credit card or other loan accounts held by a financial entity. This does not include investment accounts such as Registered Retirement Savings Plans (RRSPs). (compte financier)

Financial entity

Means a bank that is regulated by the Bank Act, an authorized foreign bank, as defined in section 2 of that Act, in respect of its business in Canada, a cooperative credit society, savings and credit union or caisse populaire that is regulated by a provincial Act, an association that is regulated by the Cooperative Credit Associations Act, a financial services cooperative, a credit union central, a company that is regulated by the Trust and Loan Companies Act and a trust company or loan company that is regulated by a provincial Act. It includes a department or an entity that is an agent or mandatary of Her Majesty in right of Canada or of a province when it is carrying out an activity referred to in section 45 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations. (entité financière)

Guarantor

A guarantor can be:

  • a medical doctor, chiropractor, or dentist;
  • a judge, a magistrate or lawyer;
  • a notary (in Quebec) or a notary public;
  • an optometrist or a pharmacist;
  • an accredited public accountant or Chartered Professional Accountant;
  • a professional engineer (P. Eng., in a province other than Quebec) or engineer (Eng. in Quebec); or,
  • a veterinarian. (répondant)
Independent

For the purposes of ascertaining client identity, the term “independent” means that the sources must be different; the information cannot be from the same issuer. (source indépendante)

Individual or person

A human being. (individu ou personne)

Institutional trust

An institutional trust is a trust that is established by a corporation, partnership or other entity for a particular business purpose and includes pension plan trusts, pension master trusts, supplemental pension plan trusts, mutual fund trusts, pooled fund trusts, registered retirement savings plan trusts, registered retirement income fund trusts, registered education savings plan trusts, group registered retirement savings plan trusts, deferred profit sharing plan trusts, employee profit sharing plan trusts, retirement compensation arrangement trusts, employee savings plan trusts, health and welfare trusts, unemployment benefit plan trusts, foreign insurance company trusts, foreign reinsurance trusts, reinsurance trusts, real estate investment trusts, environmental trusts and trusts established in respect of endowments, foundations and registered charities. (fiducie institutionnelle)

Inter vivos trust

A trust that is not created by will. This type of trust is established by a living individual for the benefit of another individual, such as a trust created by a parent for a child (also known as a living trust). Its assets can be distributed to the beneficiary during or after a settlor’s lifetime. (fiducie entre vifs)

Listed person

A listed person includes an individual, a corporation, a trust, a partnership or fund or an unincorporated association or organization that is believed to:

  • have carried out, attempted to carry out, participated in or facilitated a terrorist activity; or
  • be controlled directly or indirectly by, be acting on behalf of, at the direction of, or in association with any individual or entity conducting any of the above activities.

A listed person means anyone on a list published in the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism issued under the United Nations Act. You can consult that list of names on the Office of the Superintendent of Financial Institutions' Web site: http://www.osfi-bsif.gc.ca/Eng/fi-if/amlc-clrpc/atf-fat/Pages/default.aspx. (personne inscrite)

Money Laundering Offence

A money laundering offence involves various acts committed with the intention to hide or convert dirty money produced through criminal activity into clean money whose criminal origin is hard to trace. Criminals are always looking for ways to exchange, disguise or move money around to hide its origin. The dirty money can come from offences such as drug trafficking, bribery, fraud, forgery, murder, robbery, counterfeit money, stock manipulation, tax evasion, and copyright infringement. Dirty money can also come from illegal activities that took place outside of Canada. (infraction de recyclage des produits de la criminalité)

Money service business agent

An MSB services agent is an individual or organization authorized to act on an MSB's behalf. Do not mistake an MSB agent with a branch. If you are an MSB, an agent is a separate individual or organization that you authorize to deliver your services. If you use one or more agents to deliver your MSB services on your behalf, you need to give information about all of them in your registration form. It is your responsibility to keep your agent information up to date in your registration information. If you are an agent of an MSB, you do not have to register with us for the services you deliver for that MSB. (mandataire d’une entreprise de services monétaires)

Organization

An organization is an entity such as a corporation, a trust, a partnership, or an association. It does not include an individual. (organisation)

Original

Original refers to any paper or electronic document as it is sent from the issuer directly to the client. (version originale d’un document)

Public body
  1. any department or agent or mandatary of Her Majesty in right of Canada or of a province;
  2. an incorporated city or town, village, metropolitan authority, township, district, county, rural municipality or other incorporated municipal body in Canada or an agent or mandatary in Canada of any of them; and
  3. an organization that operates a public hospital and that is designated by the Minister of National Revenue as a hospital authority under the Excise Tax Act, or an agent or mandatary of such an organization (organisme public).
Reliable

In reference to a source, reliable means that the source is well known, reputable, and is considered one that you trust to verify the identity of the client. (source fiable)

Senior officer

A senior officer of an organization can be:

  • a director who is also a full time employee;
  • a chief executive officer, chief operating officer, president, secretary treasurer, controller, chief financial officer, chief accountant, chief auditor or chief actuary, or any individual who performs these similar duties; or,
  • any other officer who reports directly to the board of directors, chief executive officer or chief operating officer. (cadre dirigeant)
Service agreement

A service agreement is an agreement between you and another organization for you to provide any of the following MSB services:

  • money transfers;
  • foreign currency exchange; or
  • money orders, traveller's cheques or anything similar. (accord de relation commerciale)
Settlor

A settlor is an individual or entity that creates a trust with a written trust declaration. The settlor ensures that legal responsibility for the trust is then given to a trustee and that the trustee is provided with a trust instrument document that explains how the trust is to be used for the beneficiaries. A settlor includes any individual or entity that contributes financially to that trust, either directly or indirectly. (constituent)

Source

The issuer or provider of information or documents for verifying identification. (source)

SWIFT

The Society for Worldwide Interbank Financial Telecommunication (SWIFT) network is a global member-owned cooperative and an international provider of secure financial messaging services. (SWIFT)

Terrorist activity financing offence

A terrorist financing offence is knowingly collecting or giving property (such as money) to carry out terrorist activities. This includes the use and possession of any property to help carry out the terrorist activities. The money earned for terrorist financing can be from legal sources, such as personal donations and profits from a business or charitable organization. The money can also come from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion. (infraction de financement des activités terroristes)

Trust

A right of property held by one individual or entity (a trustee) for the benefit of another individual or entity (a beneficiary). (fiducie)

Trustee

A trustee is the individual or entity authorized to hold or administer the assets of a trust in the best interests of the beneficiary. (fiduciaire)

Valid

Refers to a document or information that appears legitimate or authentic and does not appear to have been altered or had any information redacted. The information must also be valid according to the issuer, for example if a passport is invalid because of a name change, it is not valid for FINTRAC purposes. (document ou renseignement valide)

Verify client identity

To refer to certain information or documentation to identify a client and ensure that their information matches what you know about them. (vérifier l’identité d’un client)

Very Large Corporation

A large corporation is one that has minimum net assets of $75 million CAD on its last audited balance sheet. The corporation's shares have to be traded on a Canadian stock exchange or on a stock exchange outside Canada that is designated by the Minister of Finance. The corporation also has to operate in a country that is a member of the Financial Action Task Force (FATF). (personne morale dont l’actif est très important)

Working Days

A working day is a day between and including Monday to Friday. It excludes Saturday, Sunday, or a public holiday. (jour ouvrable)

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