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It could replace the absence of a postal code, but would not in itself be an address for the purpose of the PCMLTFR.

I am seeking clarification on how to identify a client in a non-face-to-face situation when they have less than 3 years of credit history.

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.

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.

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 answer your question, in order to meet the obligations outlined within the PCMLTFA and its associated Regulations, it is recommended that reporting entities compare the names listed in Appendix A to current and future clients.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.The requirement to report an STR to FINTRAC is identified at section 7 of the PCMLTFA, which states that “Subject to section 10.1, every person or entity referred to in section 5 shall report to the Centre, in the prescribed form and manner, every financial transaction that occurs or that is attempted in the course of their activities and in respect of which there are reasonable grounds to suspect that (a) the transaction is related to the commission or the attempted commission of a money laundering offence; or (b) the transaction is related to the commission or the attempted commission of a terrorist activity financing offence”.Regarding the TPR obligation, subsection 7.1(1) of the PCMLTFA stipulates that “every person or entity referred to in section 5 that is required to make a disclosure under section 83.1 of the Criminal Code or under section 8 of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism shall also make a report on it to the Centre, in the prescribed form and manner”.

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