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Verifying the identity of a client that is an organization

The following are resources that may be helpful in answering your enquiry. Please familiarize yourself with them before moving on.

In brief: If your client is an “organization” you must verify the identity of both the “organization” and the instructing individual (see Law Society Rule 3-98 definition of “client” and Law Society Rule 3-102). The time requirements for verification differ. Verify the instructing individual(s) at the time that you provide legal services in respect of a financial transaction; verify the organization within 30 days of same.

Key Resources

Rules - Timing of verification: Law Society Rules 3-105 and 3-106.

Rules - Definitions of "client" and “organization”:  Law Society Rule 3-98.

Rules - Verifying an organization:  Law Society Rule 3-102(2).

Practice Resource - Client Identification, Verification and Source of Money Checklist, current to September 1, 2023;  includes Sample Agreement with Agent for Verification. (Note the changes to Law Society Rules 3-102 and 3-104 made on March 8, 2024 that affect parts of this checklist.) 

Practice Resource - Red Flags Quick Reference Guide

Additional Reading

Rules - Definitions of “financial transaction” and “money”: Law Society Rule 3-98.

Rules - Requirement to identify directors, shareholders, and owners: Law Society Rule 3-103.

Rules - Exemptions to verification requirements:  Law Society Rules 3-99 and 3-101.

Next Steps

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