Earlier this month, the Ontario Securities Commission (OSC) hosted a seminar where a FINTRAC staff member discussed registrants’ compliance obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). His presentation swerved, however, when he answered a question about what a registrant should do when the document used for identification purposes at the time of account opening expires. He said that if the identification document expired after the identification was made, the firm must gather a current, valid form of identification from the client before completing any further transactions with the client.
This response surprised many members of the audience and led to further questions during the session. After the seminar ended, the OSC and FINTRAC followed up to let seminar participants know that FINTRAC intends to clarify the responses that had been provided to certain questions during the seminar and that it will share these clarifications with all attendees. We are waiting to receive these clarifications and will keep you updated.