Client identification information depends on the information you have to confirm or obtain from your clients and the records you have to keep. Client identification information that is required to be updated generally includes:
- For an individual, the individual’s name, address, telephone number and occupation or principal business.
- For a corporation, its name and address and the names of the corporation’s directors.
- For an entity other than a corporation, its name, address and principal place of business.
Reasonable measures to keep client identification up to date include asking the client to confirm or update their information. In the case of an individual client, reasonable measures also include confirming or updating the information through the options available to identify individuals who are not physically present. This can include obtaining information verbally to keep client identification information up to date.
In the case of clients that are entities, reasonable measures to keep client identification up to date include consulting a paper or an electronic document to confirm information or obtaining the information verbally from the client.
Although the frequency with which the client identification information is to be kept up to date will vary depending on your business, you should review it at least every two years for high risk situations. When you review client identification information, you should also update the records you keep for that client.
You may want to consider establishing and implementing a timeline to update the identification information of your clients that you do not consider high risk.