Facebook Confirmation D J Effectu E Ce Compte Est D J Confirm
Rivka Licklider
Note: For specific information on when to verify the identity of a person or an entity (the timing requirement) for your business sector, refer to the related guidance by business sectors.
The requirement to verify the identity of a person or an entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations applies to all reporting entities
facebook confirmation d j effectu e ce compte est d j confirm
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It means to use the methods described in this guidance to ensure that the information in an identification document or from other informational sources matches the information that the person or entity provided.
Verifying identity is a foundational element of Canada's anti-money laundering and anti-terrorist financing regime and a key component of an RE's relationship with clients. It helps you to know your clients and to understand and assess any risk that may be associated to their transactions or activities.
You can determine whether a government-issued photo identification document is authentic, valid and current by viewing it in person, and by looking at the characteristics of the original physical document and its security features (or markers, as applicable) in the presence of the person being identified. This will allow you to be satisfied that the identification document is authentic, as issued by the competent authority (federal, provincial, or territorial government), valid (unaltered, not counterfeit) and current (not expired).
You may use the government-issued photo identification method if a person is not physically present, but you must have a process in place to authenticate the government-issued photo identification document. For instance, you could assess a document by using a technology capable of determining the document's authenticity. For example, you could:
When a person is not physically present, you must still determine whether the authenticated government-issued photo identification document is valid and current, and that the name and photo are those of the person providing the document. For example, you could:
Your compliance program's policies and procedures must describe the processes you follow to determine whether a government-issued photo identification document is authentic, whether the client is present or not, and how you will confirm that it is valid and current. Your policies and procedures must also describe the steps you use to confirm that the name and photograph are those of the person. Your processes to determine that a government-issued photo identification document is authentic, valid, and current, and the verification step (ensuring that the name and photo match the name and appearance of the person), do not need to happen at the same time. It is up to you to determine the timing, but you must complete both steps.
A credit file provides a rating on a person's ability to repay loans; however, it is possible to request a credit file to verify a person's identifying information that does not include a credit assessment. You do not need a credit assessment to verify the identity of a person. Equifax Canada and TransUnion Canada are Canadian credit bureaus that provide credit file information for identification purposes.
To use the credit file method, you must conduct the search at the time you are verifying the person's identity. A person cannot provide you with a copy of their credit file, nor can a previously obtained credit file be used.
It is acceptable to use an automated system to match the person's information with the information in the person's credit file. You may also refer to a third party vendor to provide you with valid and current information from the person's credit file. A third party vendor is a business that is authorized by a Canadian credit bureau to provide access to Canadian credit information.
If any of the information provided by the person (name, address or date of birth) does not match the information in the credit file, you cannot use that credit file to verify the identity of the person. You will need to use another credit file from a different provider (credit bureau or third party vendor) or use a different method (for example, the government-issued photo identification method or the dual-process method) to verify the person's identity.
On occasion, information found in the credit file may contain a variation on the name or a discrepancy in the address that was provided to you by the person. In these instances, you must determine whether the information in the credit file matches the information provided by the person. For example:
Your compliance program's policies and procedures must describe the processes you will follow to verify a person's identity using the credit file method and how you will ensure that the information is valid and current. It should also include the steps you will take if the information is not valid and current (for example, search a different credit file, use another method, stop the transaction, etc.).
The information you refer to must be valid and currentFootnote 8 and come from two different reliable sources. This information could be found in statements, letters, certificates, forms or other information sources that can be provided through an original version or by another version of the information's original format such as a fax, a photocopy, a scan, or an electronic image. For example, you can rely on a fax, photocopy, scan or electronic image of a government-issued photo identification document as one of the two pieces of information required to verify a person's identity.
You cannot use the same source for the two categories of information you choose to verify a person's identity.Footnote 9 For example, you cannot rely on a bank statement from Bank A that includes the person's name and address and another bank statement from Bank A that includes the person's name and confirms that the person holds a deposit account, as Bank A would be the same source of both categories of information. You can, however, refer to a bank statement from Bank A that contains the person's name and confirms that the person holds a deposit account, and rely on an electronic image of a driver's licence to confirm the person's name and address.
Referring to information from one reliable source that includes the person's name and address and confirming that this matches the information provided by the person, and referring to information from a different reliable source that includes the person's name and date of birth and confirming that this matches the information provided by the person.
Referring to information from one reliable source that includes the person's name and address and confirming that this matches the information provided by the person, and referring to information from a different reliable source that includes the person's name and a financial account (specifically, a deposit account, a prepaid payment product account, a credit card account or a loan account) and confirming this information.
Referring to information from one reliable source that includes the person's name and date of birth and confirming that this matches the information provided by the person, and referring to information from a different reliable source that includes the person's name and a financial account (specifically, a deposit account, a prepaid payment product account, a credit card account or a loan account) and confirming this information.
Note: If the information does not match the information provided by the person, you cannot rely on it. For example, it is not acceptable to rely on information if the account number or number that is associated with the information is truncated or redacted. On occasion, information from a source may contain a variation on the name of the client or a typo in the client's address. In these instances, you must determine whether the information matches the information provided by the person. If it is a slight typo in the address or a misspelled name, you may determine that the information still matches what the person provided. However, in the case of an incorrect date of birth, it is more likely that you will determine that the information does not match. In this case, you cannot rely on the information from this source for identification purposes. You must obtain information from a different source under the dual-process method or use a different method (for example, the government-issued photo identification method or the credit file method) to verify the person's identity.
A reliable source of information is an originator or issuer of information that you trust. To be considered reliable, the source should be well known and considered reputable. For example, a reliable source could be the federal, provincial, territorial or municipal levels of government, Crown corporations, federally regulated financial institutions, or utility providers. Social media is not an acceptable source of information to verify a person's identity. Also, the source cannot be the person whose identity is being verified, nor you, the RE who is verifying identity.Footnote 10 See Annex 5 for a table of examples of reliable sources of information for the dual-process method.
A Canadian credit file can be used as one of the two pieces of information required to verify the identity of a person under the dual-process method. Specifically, it can be used to confirm the person's name and address, name and date of birth, or to confirm the person's name and confirm that the person has a credit card account or a loan account. If you use a credit file as one of the information pieces for the dual-process method, it must have existed for at least six months.Footnote 11
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