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.)