Appendix H: Client Identification and Verification Requirements Comparison Chart

Requirement

AML Rules

IIROC Rules

Beneficial owners and beneficiaries
(information firms must collect on the client)

Information on the ownership, control and structure of the entity

And

Corporations :

  • Names of all directors
  • Names & addresses of those who own or control  25% or more of the shares of a corporation 

 

Entities other than corporations:

  • names and addresses of those who own or control 25% or more of the entity

Trusts :

  • the names and addresses of all trustees and all known beneficiaries and settlors of the trust

Identity of:

  • beneficial owners of more than 25% of a corporation
  • individuals who exercise control over affairs of a partnership or trust

Names & addresses of:

  • all directors of a corporation
  • all trustees, known beneficiaries and settlors of a trust

Establishing identity
 

  • confirm information
  • establish information (as per s.3206 in Appendix C)

Timing
(how long firms have to verify/establish/ confirm the information)

Entities - 30 days

 

Individuals – before the first transaction other than the initial deposit

  • 30 days

Exceptions

  • financial entity or affiliate that carries banking, life insurances or securities activities (bank, credit union, caisse populaire, trust and loan companies)
  • registered plans
  • regulated pension fund
  • securities dealer
  • investment fund
  • life insurance company
  • public body or large publicly-traded corporation
  • Canadian registered firm
  • Canadian investment fund
  • Canadian financial institution
  • Schedule III bank
  • public body or large publicly-traded corporation

(Note: the Rule Amendments clarify that foreign financial entities are not exempt.)