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In Canada - Using an agent or a mandatary to verify the identity of a person

January 31, 2025 posted by Steve Brownstein

Using an agent or a mandatary to verify the identity of a person on your behalf

You may verify the identity of a person by using an agent or mandatary to carry out the verification on your behalf, in accordance with the government-issued photo identification method, the credit file method, or the dual-process method.Footnote

You may rely on the measures that were previously taken by an agent or mandatary to verify the person's identity, if the agent or mandatary was:Footnote

  • acting in their own capacity at the time, whether or not they were required to use the methods in accordance with the PCMLTFR; or
  • acting as an agent or mandatary under a written agreement or arrangement that was entered into with another RE, for the purposes of verifying a person's identity using either the government-issued photo identification method, the credit file method or the dual-process method, or if the measures were taken prior to June 1, 2021, using the methods in accordance with the PCMLTFR that were in place at the time. 

To use an agent or mandatary to verify the identity of a person you must:Footnote

  • have a written agreement or arrangement in place with the agent or mandatary before you use them;Footnote
  • obtain, as soon as feasible, all of the information that  the agent or mandatary referred to in order to verify the person's identity, and the information that the agent or mandatory confirmed as being that of the person;Footnote and
  • be satisfied that:
    • the information that the agent or mandatary confirmed as being that of the person is valid and current, and
    • the person's identity was verified using the government-issued photo identification method, the credit file method or the dual-process method, or, if the person's identity was verified prior to June 1, 2021, using the methods in accordance with the PCMLTFR in place at the time.Footnote
    •  

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