•While government issued 

identification is required to verify the 
existence of an individual, there is 
no explicit mention that independent 
address verification is required. 

 

•It is industry standard to apply a 25% 

shareholding threshold in order to 
classify an individual as a “relevant 
beneficial owner” who requires 
identity verification irrespective of 
the risk classification. In comparison, 

in the UK for example, it is common 
practice that this threshold is 
reduced to 10% for higher risk 
customers as a form of additional 
due diligence to mitigate the higher 
risk imposed.

While Canada plays AML/CTF catch-up, 
the world is not static. Global AML/CTF 
regulations and expectations continue to 
evolve which means that there will be 
continued changes and enhancements 

to Canada’s AML/CTF rules and 
regulations.

It is clear that Canada is forging its way 
forward but there is much to do to 
converge standards with those leading 
the global fight. In the end, the message 
for Canadian companies is that change 
in the world of AML/CTF regulation and 
compliance must be seen as the new 
normal.

© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms 
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms 
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

At Risk  |  Volume 7, No. 1  |  13