Client verification Current

Verifying an identity document came from a reliable, independent source

Reliable and independent are two separate tests, and both have to pass.

When you're not using a government-issued photo ID or a credit file, FINTRAC's dual-process method depends on the sources behind each piece of information actually being reliable and independent of each other. This guide sets out what that means in practice. It is general information, not legal or compliance advice.

Action plan

1 Know what the dual-process method actually requires It's two pieces of information from two different sources confirming specific facts, not just two documents.

FINTRAC's guidance describes the dual-process method as needing two pieces of information from different reliable sources, together confirming the client's name plus one of: address, date of birth, or confirmation of a financial account such as a deposit account, credit card, or loan. Check that the combination you're relying on actually confirms one of these pairings, not just that you're holding two documents.

  • Confirm the two pieces of information together cover name plus address, name plus date of birth, or name plus a financial account
  • Don't treat any two documents as automatically sufficient
  • Record which specific combination was used for each client

Done when: The two pieces of information used together confirm one of FINTRAC's accepted dual-process combinations

FINTRAC: methods to verify the identity of persons and entities
2 Check that each source is genuinely reliable A reliable source is well known and reputable, and it can't be the client or your own firm.

FINTRAC's guidance describes a reliable source as one that is well known and considered reputable, such as a government body, a Crown corporation, a federally regulated financial institution, or a utility provider. It also makes clear the source can't be the person whose identity is being verified, and it can't be your own firm either. Check each source against this before treating it as satisfying the method.

  • Confirm each source is a well known, reputable body of the kind FINTRAC describes
  • Don't accept the client's own statement as one of the two sources
  • Don't rely on your own firm's records as one of the two sources

Done when: Each source relied on has been checked against FINTRAC's description of a reliable source

FINTRAC: methods to verify the identity of persons and entities
3 Don't use the same source twice for both pieces of information Two documents from one issuer don't count as two independent sources.

FINTRAC's guidance is explicit that the two sources used for the dual-process method must be different from each other, for example two statements from the same bank don't satisfy the method. Check that the two pieces of information actually come from two different issuing sources before treating verification as complete.

  • Confirm the two pieces of information come from two genuinely different sources
  • Don't accept two documents issued by the same organisation as satisfying the method
  • Record which two distinct sources were used for each client

Done when: The two sources used for dual-process verification have been confirmed as genuinely independent of each other

See requesting individual identity documents