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Client Identification, Verification, and Monitoring File Forms

 On January 1, 2022, by-law amendments to fight money laundering and terrorist financing come into effect. These amendments include changes to licensees’ obligations to identify and verify the identity of clients. In certain circumstances, there are also new requirements to obtain source of funds information and periodically monitor the professional relationship with the client. For more information about the changes and new requirements, licensees should consult the related resources below.

About the File Forms

The Law Society has developed the following file forms for use by licensees on or after January 1, 2022:
Client Identification Form (Individual or Organization) (.docx)
Client Verification Form (Individual) (.docx)
Client Verification Form (Organization) (.docx)

Sample Monitoring Record (.docx)

The file forms are intended to support licensees with

  • determining the applicable requirements in their matter
  • identifying the information and documents required to meet their professional obligation to know their client
  • understanding their client’s financial dealings in relation to the retainer
  • managing risk arising from the professional business relationship with the client, and
  • documenting their due diligence.

In certain circumstances, it may not be necessary to obtain all the information outlined in the file forms (e.g., if an exemption applies). In other cases, additional information or due diligence may be required (e.g., if the transaction is high-risk). Licensees must exercise their professional judgment in completing these forms.   

How to Use File Forms

  1. Review the client identification, verification, source of funds, and monitoring resources below and the requirements set out in By-Law 7.1 to ensure you understand what is required. If you have questions about any of your obligations, you should consider contacting the Law Society’s Practice Management Helpline.
  2. When retained to provide legal services, select and download the applicable form (all forms are available in Word format).
  3. Review the requirements set out in each section of the applicable file form and complete each part of the form, as applicable. Inapplicable sections should be marked as “Not Applicable” or “N/A” with a brief explanation.  
  4. If there is more than one client or third party who you are required to identify or verify, you should complete one form for each client or third party.
  5. Retain the completed file form(s) as part of your paper or electronic client file in accordance with the document and record retention requirements set out in By-Law 7.1.

Related Resources

Overview of Requirements

Examples and Defined Terms

FAQs

Risk Assessment Worksheets and Case Studies

Terms or Concepts Explained