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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 (Law Society Rule 3-98 definition of “client” and Law Society Rule 3-102). The timing 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

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

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

Rule - Identifying directors, shareholders and owners:  Law Society Rule 3-103

Rule - Record keeping and retention:  Law Society Rule 3-107

Practice Resource - Client Identification, Verification and Source of Money Checklist

Practice Resource - Red Flags Quick Reference Guide

Practice Resource - Client Identification and Verification - Top 10 tips

Practice Resource Client ID & Verification - Frequently asked questions 

Additional Reading

Practice Resource - Anti-Money Laundering Webinar 2024 at 1:55

Practice Resource - Forming companies and other structures - managing the risk, Spring 2021 Benchers' Bulletin

Practice Resource - Client ID & verification resources web page

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

Rules - Exemptions to verification requirements:  Law Society Rules 3-99(2(a) and 3-101

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