FINTRAC Policy Interpretations

Business Relationship

Definition of Purpose of the Business relationship and Intended Nature of the Business Relationship

Question:

I would like FINTRAC to define and clarify these 2 terms:

a) Purpose of the Business Relationship

b) Intended Nature of the Business Relationship

Answer:

Pursuant to section 145 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, every person and entity that enters into a business relationship must keep a record that sets out the purpose and intended nature of the business relationship.

The “purpose and intended nature” of the business relationship is a single concept that may be kept in one record. This information should reflect why and/or how an individual or entity expects to use your business’ products and services, and could be inferred by the types of transactions conducted. You do not need to create a new record if you are able to retrieve this information from the records you currently hold.

The reason for getting this information, and keeping a record of it, is to allow you to anticipate the transactions and activities of your client and to assist you in determining if an activity, or activities, are not in line with your expectations and may, therefore, warrant being more frequently monitored or reported. You also have to review this information on a periodic basis and keep it up to date. This is done to ensure that you continue to understand your client’s activities over time so that any changes can be used to assess or detect high-risk transactions and activities.

Date answered: 2014-03-03

Answer updated on: 2021-08-20

PI Number: PI-6107

Activity Sector(s): Accountants, British Columbia notaries, Casinos, Dealers in precious metals and stones, Financial entities, Life insurance, Money services businesses, Real estate, Securities dealers

Obligation(s): Business Relationship

Guidance: Business relationship requirements

Regulations: 145

Date Modified: