Canada: corporate bank account opening

Verify the corporation's existence, name and address and obtain its directors' names using the methods permitted by FINTRAC. A certificate of corporate status, an annual filing or another qualifying corporate record can provide the evidence. Search the federal or provincial registry where the company was incorporated; federal incorporation and provincial registration are separate records.

Ownership information and its accuracy

Obtain the names and addresses of individuals who directly or indirectly own or control at least 25% of shares, and information establishing the corporation's ownership, control and structure. Take reasonable measures to confirm its accuracy, using shareholder records, corporate filings and the relevant documents for intermediate entities.

Where the required information cannot be obtained or its accuracy cannot be confirmed, FINTRAC requires specified follow-up: reasonable measures concerning the chief executive or equivalent, high-risk treatment and the corresponding special measures. Record the failed steps and follow-up rather than substituting an unexplained director's name.

Signatories and the proposed account

Verify the identity of the people authorised to give account instructions as required. FINTRAC provides an exception after three authorised people have been verified; document its use rather than treating all signatories as automatically exempt.

Record the account's intended use, expected activity and third-party arrangements. Apply the relevant PEP, head-of-international-organisation and high-risk measures and resolve sanctions issues before approval.

Conduct ongoing monitoring and keep client information current. Obtain revised ownership or mandate evidence when those facts change and retain the verification and monitoring records under their applicable retention triggers.