Using an Agent to Verify Identity
Did you know you can always use an agent to verify your client’s identity?
Use an agent to verify the identity of any client you cannot meet in person, whether that client is outside the country or province or just not able to meet with you face to face.
Who can act as an agent?
There are no set qualifications or credentials for who can act as an agent, so use your professional judgement.
Find an agent who is reputable, reliable, accountable, and, if possible, familiar with anti-money laundering due diligence requirements. Lawyers, notaries, accountants, investment advisors, securities dealers, real estate agents, and people who work in the financial sector would be familiar with anti-money laundering due diligence requirements. Peace officers or justices of the peace would also be appropriate.
If the client is in a country identified as high risk for money laundering by the Financial Action Task Force or the Canadian government, check if an embassy or consulate might offer verification of identity services.
Who should choose the agent?
You should always choose the agent. Don’t let the person whose identity is being verified select the agent.
If your client does suggest a potential agent, do your due diligence and investigate that agent. For example, if the proposed agent is a member of a regulated profession, like a lawyer or an accountant, check their status with their regulator.
If you cannot identify a suitable candidate to act as agent, reach out to the local regulator for the legal profession. They may be able to suggest someone or may have a list of lawyers in good standing in that jurisdiction.
How to use an agent?
You must have a written agreement with the agent. The agreement may be set out in a letter or email. Give the agent enough detail so they understand the purpose of the arrangement and what they are expected to do.
What Should be in the Agent Agreement/Letter?
- Be sure the agreement includes the agent’s full name, occupation and business address.
- Confirm which method the agent will use or has used to verify the client’s identity. Most often, you will be asking the agent to verify identity using government issued photo ID, but they can also verify by virtual authentication with a DIACC software provider, or two documents from a reliable source or even the credit check method.
- The agent should send you copies of the information and documents they obtained to verify the client’s identity.
- The agent should confirm the date when they verified the identity and you should record the date the agent delivered the information to you.
Previous Verification Works
If an agent has previously verified the clients Identity, you can rely on that verification. For instance, you can accept a verification obtained by the real estate agent on a transaction.
Ask the agent to send you an email that gives their full name, occupation and business address, tells you how and when they verified the client’s identity and have them provide copies of the information they relied upon.
You can also take the same steps when a client is being referred to you by a lawyer or accountant who has previously verified that client’s identity.
For more information visit the Anti-Money Laundering Resource Library:
