Client intake Current

Requesting identity documents from an individual client in Canada

Ask for evidence that matches one of FINTRAC's accepted methods, not an informal mix.

Firms captured by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act generally need to identify an individual client in connection with certain activities before acting for them. This guide sets out a practical way to request that evidence. It is general information, not legal or compliance advice.

Action plan

1 Confirm the activity you're doing for the client actually triggers identification Identification requirements attach to specific activities, not to every engagement.

FINTRAC's guidance for accountants describes the activities that bring a firm within the Act: receiving or paying funds or virtual currency, purchasing or selling securities, real property, or business assets or entities, or transferring funds, virtual currency, or securities on a client's behalf. Check the specific activity involved in this engagement against that list before assuming identification is or isn't required, and note that FINTRAC's guidance is explicit this can apply even where the service is provided voluntarily.

  • Match the specific engagement activity against FINTRAC's list of triggering activities for accountants
  • Don't assume routine advisory or compilation work automatically triggers the requirement
  • Don't assume it doesn't apply just because no fee has been charged yet

Done when: The specific engagement activity has been checked against FINTRAC's triggering-activity list, not assumed

FINTRAC: accountants as a reporting sector
2 Explain the request plainly before asking for documents A short, matter-of-fact explanation generally reduces friction and follow-up questions.

Clients generally respond better to an identity request when they understand it's a standard step for this kind of engagement, not a judgement about them personally. A short explanation of what's needed, why, and what will happen to the documents once received helps set that context before the list of documents lands in their inbox.

  • Explain that identity evidence is a standard part of onboarding for this kind of engagement
  • Give the client a short, specific list of exactly what's needed
  • Explain briefly what will happen to the documents once received

Done when: The client has been told why identity evidence is needed before being asked to provide it

3 Ask for evidence that matches one of FINTRAC's accepted methods Request documents that map to a named method, so verification doesn't stall on evidence that can't actually be used.

FINTRAC's guidance sets out several named methods for verifying an individual's identity, including the government-issued photo identification method, the credit file method, and the dual-process method. Ask the client for evidence that maps to whichever method your firm intends to use, for example a current government-issued photo identification document, rather than requesting documents in general terms and sorting out which method they satisfy afterwards.

  • Decide which FINTRAC-accepted method you intend to use before requesting documents
  • Ask for the specific evidence that method requires, not a general document list
  • See the separate guide on verifying the evidence once it's provided

Done when: The client has been asked for evidence matching a specific FINTRAC-accepted verification method

FINTRAC: methods to verify the identity of persons and entities
4 Store what's collected as part of your client due diligence records Keep collected evidence with your other due diligence records once it arrives.

Once identity evidence is collected, keep it with your firm's other client due diligence records, with access limited to people who need it. Vertical Flows can structure the intake and evidence-storage workflow this relies on. It does not set your firm's record-keeping policy.

  • Store collected identity evidence with your other client due diligence records
  • Limit access to people who need it
  • See the separate guide on storing this evidence securely

Done when: Collected identity evidence is stored with other due diligence records and access is limited

See storing client identity evidence securely