It depends. If you are engaged in or giving instructions in respect of the receipt, transfer, or payment of those shares then, unless an
exemption applies, you must verify the identity of your client. This would include, for example, preparing a document that directs how those shares are to be received, paid, or transferred.
If you are not, then you do not need to verify the client’s identity.
Note that licensees must keep a record of all negotiable or valuable property (other than money) that they receive that is to be held in trust for clients. For more information, see Part V of
By-Law 9.