When to ID your clients

ID individuals

When you:

  • receive $10,000 or more in cash
  • sell or cash $3,000 or more of traveller's cheques, money orders, or anything similar
  • exchange currency of $3,000 or more for another
  • send money transfers of $1,000 or more
  • suspect that a transaction, or an attempted transaction, of any amount, is related to a money laundering offence or a terrorist financing offence

Exceptions for individual ID

You do not have to ID:

  • an individual who is conducting a transaction on behalf of their employer under a service agreement, unless you suspect that the transaction is related to money laundering or terrorist financing
  • an individual who is involved in, or attempts, a transaction you think is suspicious if:
    • you believe that identifying the individual would inform them that you are sending a suspicious transaction report
    • you already identified them and have no doubts about that previous ID information
  • an individual that you have already identified if you recognize them (visually or by voice) in future transactions. But, if you have any doubts about the ID information previously collected, you have to ID the client again

ID organizations

When you:

  • enter into a service agreement

Exceptions for organization ID

You do not have to ID an organization if it is a public body or a large corporation.

Definitions

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.

branch

A branch is a part of your own business at a distinct location other than your main office. Do not mistake it with an agent, which is a separate business.

cash

Cash means money in circulation in any country. These are bank notes or coins.

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.

electronic funds transfer

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.

financial entity

A financial entity means:

  • a bank or a foreign bank authorized to operate in Canada
  • a credit union or caisse populaire
  • a financial services cooperative or a credit union central (when they offer financial services to anyone other than a member entity of the credit union central)
  • a trust or loan company
  • an agent of the Crown that accepts deposit liabilities, like a provincial savings office
guarantor

A guarantor can be:

  • a dentist, a medical doctor or a chiropractor
  • a judge, a magistrate or lawyer
  • a notary (in Quebec) or a notary public
  • an optometrist or a pharmacist
  • an accredited public accountant (APA), a chartered accountant (CA), a certified general accountant (CGA), a certified management accountant (CMA), a public accountant (PA) or a registered public accountant (RPA)
  • a professional engineer (P. Eng., in a province other than Quebec) or engineer (Eng. in Quebec)
  • a veterinarian.
large corporation

A large corporation is one that has minimum net assets of $75 million 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).

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.

organization

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

public body

A public body means any of the following or their agent:

  • a Canadian provincial or federal department or Crown agency
  • an incorporated Canadian municipal body (including an incorporated city town, village, metropolitan authority, district, county, and so on)
  • a public hospital in Canada
reporting entity

A reporting entity is an individual or an organization that has to report certain transactions to us. They are:

  • financial entities
  • life insurance companies, brokers and agents
  • securities dealers
  • money services businesses
  • agents of the Crown that sell money orders
  • accountants and accounting firms (when carrying out certain activities on behalf of their clients)
  • real estate brokers, sales representatives and developers (when carrying out certain activities)
  • casinos
  • dealers in precious metals and stones
  • public notaries and notary corporations of British Columbia (when carrying out certain activities on behalf of their clients)
  • for the purposes of suspicious transactions, employees of these reporting entities
reasonable measures

Reasonable measures to confirm the accuracy of beneficial ownership information would include asking the client to provide documentation. You can rely on the information provided by clients, but you should use discernment when determining if the documentation is appropriate.

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
  • any other officer who reports directly to the board of directors, chief executive officer or chief operating officer
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
  • money orders, traveller's cheques or anything similar
terrorist 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.

working days

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

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