6.16 – Using an Agent

You may use an agent in any circumstance to obtain required verification information and must use an agent when the client or third party is not physically present in Canada. Although the Rules do not specify who may act as an agent, you must use due diligence to ensure the agent is reputable and capable. Further, you may rely on an agent’s previous verification of a client or third party in certain circumstances.

When retaining an agent to verify identity, you must enter into an express written arrangement or agreement with the agent. See Rule 1545(2).

When using an agent, your records should include, through the agreement itself and the report from the agent:

• the full name of the agent who verified the individual’s identity,
• the agent’s status or occupation and business address,
• the client identification method the agent used,
• copies of the information and documents obtained by the agent to verify the individual’s identity, and
• the date on which the agent verified the individual’s identity.