Who are you? FINTRAC wants to know

FINTRAC, the Canadian FIU (financial intelligence unit, responsible for AML enforcement), has issued a new guideline specifying how firms must establish the identity of their clients. The Guideline will be mandatory next June, after a 1-year transition period.

Mr. Watchlist will cover this Guideline, section by section, in the coming weeks.

But here are some quick summaries – this chart lists the direct methods of ascertaining identify:

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 (name, address, date of birth, financial account)
  • Account or reference number
  • Date of verification

And the second chart of who can identify the client for you:

 

Client 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

Link:

FINTRAC Guideline

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