How do I ID a Corporation?

🧾 How to Identify a Corporation (Updated FINTRAC Requirements – Effective October 1, 2025)

When your client is a corporation or other entity, remember:

The client is the corporation itself, not just the signing officer.

These steps reflect the new FINTRAC and PCMLTFA requirements, including the CBCA “Individuals with Significant Control (ISC)” registry and beneficial ownership confirmation process.

Step 1 – Verify the Corporation Exists

Collect and record:

• Legal name of the entity
  
  

• Business Number (BN) (from CRA or registry)
  
  

• Registered/legal address and jurisdiction of incorporation
  
  

• Type of entity (corporation, partnership, trust)
  
  

• Nature of business
  
  

• Proof of registration:
  
  

  • Certificate of Incorporation, or
    
    

  • Current corporate registry print/profile, or
    
    

  • Equivalent official registry extract
    
    

✅ Record: the source, date checked, and who verified the information.
📎 The ReallyTrusted Corporate ID form captures this automatically when documents are uploaded.

Step 2 – Obtain Director Information

• List the names of all current directors (found in registry documents or annual returns).
  
  

• Directors do not need to be ID’d unless they are also a beneficial owner or authorized signing officer.
  
  

Step 3 – Determine Beneficial Ownership (BO)

A beneficial owner is any individual who:

• Owns or controls 25% or more of the corporation, directly or indirectly, or
  
  

• Controls through other means, such as voting rights, shareholder agreements, or influence.
  
  

For each beneficial owner, record:

• Full legal name
  
  

• Date of birth
  
  

• Address
  
  

• Occupation
  
  

• Ownership or control percentage
  
  

If no one meets the 25% threshold, record the most senior managing officer as the fallback.

🧩 Steps to Confirm BO:
You must record how the information was confirmed — e.g., documents reviewed, registries checked, individuals consulted, and the outcome.
This replaces the older “reasonable measures” wording.

Step 4 – Beneficial Ownership Declaration

• Use the ReallyTrusted Corporate ID form or your brokerage’s Beneficial Ownership Declaration form.
  
  

• Must be signed by an authorized signing officer.
  
  

• If beneficial owners exist: record and verify each one.
  
  

• If no beneficial owner ≥25%: complete a negative confirmation and ID the senior managing officer.
  
  

Step 5 – CBCA High-Risk Corporations (NEW)

For corporations incorporated under the Canada Business Corporations Act (CBCA) that are assessed as high risk:

1. Consult the Corporations Canada ISC Registry
   
   

   • Search for the corporation’s “Individuals with Significant Control.”
     
     

2. Compare that registry data with your recorded BO information.
   
   

3. If there’s a material discrepancy:
   
   

   • Attempt to resolve it within 30 days.
     
     

   • If unresolved, report the discrepancy to Corporations Canada.
     
     

🗂️ Keep a copy of the discrepancy report or resolution in your deal file.

Step 6 – Sanctions & PEP/HIO Screening

Use ReallyTrusted to screen the corporation, beneficial owners, and senior officers for:

• Sanctions list matches
  
  

• Politically Exposed Person (PEP) or Head of International Organization (HIO) status
  
  

🚨 Any match or uncertainty = immediate escalation to the Broker or Compliance Officer.

Step 7 – Ongoing Monitoring

• Reassess beneficial ownership and ISC information at every new transaction.
  
  

• Update corporate and BO records if changes occur.
  
  

• Maintain documentation for at least five years after the last transaction.
  
  

✅ Key Takeaways for Realtors

• Always treat the corporation as your client.
  
  

• Beneficial Ownership (BO) identification is mandatory — not optional.
  
  

• Record the steps taken to confirm ownership and existence.
  
  

• Use ReallyTrusted Corporate ID for automatic recordkeeping and screening.
  
  

• Escalate if BO cannot be confirmed or if any information conflicts with the registry.
  
  

📎 Downloadable Resource:
[Corporate Identification & Beneficial Ownership Checklist (PDF)]