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More specifically, this Operational Alert provides specific guidance to Canadian reporting entities about named foreign financial entities (noted in Appendix A) through which the Canadian financial system could be exposed to Daesh-related terrorist financing.In this context, FINTRAC is reminding all reporting entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations of their obligations to submit suspicious transaction reports (STR) and terrorist property reports (TPR) to FINTRAC and to risk assess their clients accordingly.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.
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.
That said, if the legal land description rather refers to an area or a parcel of land on which multiple properties are located, the legal land description would not, in this case, be sufficient.
Clients should be assessed as high-risk as applicable, and prescribed special measures must be applied, as required under section 71.1 of the PCMLTFR.
Date answered: 2017-03-07PI Number: PI-7660Activity Sector(s): Financial entities Obligation(s): Ascertaining Identification, Compliance Regime, Reporting Guidance: 4, 5Regulations: 71(1)c)Act: 7, 7.1(1) What types of foreign documents are acceptable to ascertain the identity of clients according to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations?
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.FINTRAC has previously indicated that the address referred to in the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) is the physical address where the client lives or where the physical location of the place of business is found.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.FINTRAC’s Guideline 5: Submitting Terrorist Property Reports to FINTRAC, and FINTRAC’s website further indicate that a TPR must be sent to FINTRAC, without delay, when reporting entities have property in their possession or control that they know is owned or controlled by or on behalf of a terrorist or a terrorist group.