Verifying the Identity of a Money-Services Business Customer
A money-services business (MSB) must verify the identity of its customers (except for customers using its automated teller machines [ATMs]) before providing a money service to them. The MSB must get the following basic information from each customer:
- the customer's name;
- the customer's address;
- the customer's phone number.
The MSB also has to get additional information from a customer to verify their identity if the customer's transaction is above a certain amount.
An MSB that is unable to verify the customer's identity must refuse to provide a money service under the Money-Services Businesses Act.
Obligation to verify customer identity
The MSB has to get additional information from a customer to verify their identity in the following cases:
- The customer wants to conduct a transaction totalling $3,000 or more involving the issue or redemption of traveller's cheques, money orders or bank drafts.
- The customer wants to conduct a foreign currency exchange transaction totalling $3,000 or more.
- The customer wants to conduct a funds transfer transaction totalling $1,000 or more.
- The customer wants to cash a cheque (regardless of the amount).
An MSB must verify the identity of all customers conducting off-site transactions.
The MSB must verify the identity of all co-contracting parties it deals with in connection with its money-services activities, regardless of the amount or the nature of the contract.
Personal information collected when verifying customer identity
Personal information | Natural person | Legal person |
---|---|---|
Date of birth | Yes | No |
Main occupation or nature of professional activities | Yes | No |
Nature of business activities | No | Yes |
When a third party conducts a transaction on behalf of a customer, the MSB must get the same information from the third party as it does from any other customer. The MSB must also ask for a document that certifies that the third party is authorized to act on behalf of a customer.
The MSB must verify the identity of all co-contracting parties with whom it deals in connection with its money-services activities in the same way it verifies the identity of its other customers.
Verification methods
Customer identity is verified differently for in-person transactions and off-site transactions.
In-person transaction
At the time of an in-person transaction, the MSB must collect the necessary information for verifying a customer's identity. To do so, the MSB must use one of the following methods, as applicable:
- In the case of a natural person, the MSB must ask to see an original of a photo identification document issued by a government (or a government department or agency) that includes the person's name and date of birth. It is strictly prohibited to copy an identification document.
- In the case of a business, the MSB must obtain a confirmation of the business's legal existence (for example, by verifying the business's registration in the Québec enterprise register).
Off-site transaction
At the time of an off-site transaction, the MSB must collect the necessary information for verifying a customer's identity. To do so, the MSB must use one of the following methods:
- It must obtain the account or other document number that it issued to the customer and in respect of which the customer's identity was verified by the MSB according to the applicable regulations.
- It must obtain a confirmation that the customer has a deposit account at a financial institution in respect of which the customer's identity was verified by that institution at the time the account was opened.
- It must obtain confirmation of a transaction using a bank card issued by a financial institution in the name of the customer and in respect of which the customer's identity was verified by that institution at the time the card was issued.