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The risk assessment must take into consideration the reporting entity’s: • clients and business relationships, • products and delivery channels, • geographic location of its activities, and • any other relevant factor(s).
Therefore, to answer your question, in order to meet the obligations outlined within the PCMLTFA and its associated Regulations, it is recommended that reporting entities compare the names listed in Appendix A to current and future clients.
Specifically, i am asking whether a proof of an account held with a foreign financial institution or proof of name and address via a foreign utility bill can be used as a document to ascertain the identity of client As explained at subsection 64(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), a person’s identity can be ascertained; (a) by referring to an identification document that contains their name and photograph and that is issued by the federal government or a provincial government or by a foreign government that is not a municipal government, and by verifying that the name and photograph are those of the person; (c) by referring to information that is in their credit file — if that file is located in Canada and has been in existence for at least three years — and by verifying that the name, address and date of birth in the credit file are those of the person; (d) by doing any two of the following: (i) referring to information from a reliable source that includes their name and address, and verifying that the name and address are those of the person, (ii) referring to information from a reliable source that includes their name and date of birth, and verifying that the name and date of birth are those of the person, or (iii) referring to information that includes their name and confirms that they have a deposit account or a credit card or other loan account with a financial entity, and verifying that information.
Subsection 64(1.3) of the PCMLTFR requires that “For the purposes of subparagraphs (1)(d)(i) to (iii), the information that is referred to must be from different sources, and neither the person whose identity is being ascertained nor the person or entity that is ascertaining their identity can be a source.” Additionally, subsection 64(1.4) of the PCMLTFR stipulates that “If a document is used to ascertain identity under subsection (1), it must be original, valid and current.
From the questions you have asked, it appears that you are referring to what has been titled the “dual process method” in the FINTRAC Guideline.
As indicated above, the dual process method involves referring to documents or information from two reliable and independent sources to ascertain the person’s name and address, name and date of birth, or name and that they have a financial account.
In cases where the client resides in an area where there is no civic address, a description, in as much detail as possible, of all information or features that may be useful to locate the physical location of the person is required.
Therefore, to answer your question, a mobile service provider may be referred to as one acceptable source to ascertain a client’s name and address under the dual process method, so long as it meets all of the requirements and accurate records can be kept.
A reporting entity must be able to demonstrate that it referred to two independent and reliable sources when using the dual process method, as per the PCMLTFR.
Also, the source cannot be the reporting entity, or the client; it must be independent.
As outlined at paragraph 64.2(d) of the PCMLTFR, when the dual process method is used to ascertain the identity of a client, a record must be kept that includes the person’s name, the date on which this method was used, the source of the information, the type of information referred to, and the account number included in it or a number associated with the information if no account number exists.
Therefore, to address your question, it has been determined that a legal land description can be acceptable, so long as the legal land description is specific enough to pinpoint the physical location where the client lives.