Part 2 of 2: Know Your Client (KYC) — Simple Overview

🧾 What Is a Listed Person or Entity?

People or groups considered high risk based on Canadian laws.

• From March 2, 2025:
  • Terrorist group (Criminal Code)
  • Subject of UN orders
  • Foreign state under UN Act
• From October 1, 2025:
  • Foreign state under Canadian sanctions
  • Subject of Canadian sanctions orders
  • Named under Sergei Magnitsky Law

Reference: PCMLTFA, S.C. 2000, c 17, s. 2(1)

⚖️ Check Sanction Lists

• United Nations Consolidated List
• Canadian Autonomous Sanctions List
• Criminal Code Terrorist Entities – Public Safety Canada

🚨 What Is a Terrorist Group?

Defined as:

• Group that carries out or supports terrorism
• Officially listed group
• Association of terrorist groups

💵 What Is a Money Services Business?

If you offer financial services in Canada, you may be a money services business.

• Foreign exchange
• Transferring money
• Issuing or redeeming negotiable items
• Dealing in virtual currencies
• Other prescribed services

Reference: S.C. 2000, c 17, s. 5(h); SOR/2007-121, s. 1; SOR/2002-184, s. 1(2)

🏛️ Politically Exposed Domestic Person

Someone who holds or held an important position in Canadian federal or provincial government:

• Governor General or Premier
• Member of Parliament or provincial legislature
• Deputy minister, ambassador, military general
• President of government corporation
• Judge of higher courts
• Political party leader
• Mayor or similar role

Reference: PCMLTFA, S.C. 2000, c 17, s. 9.3(3)

🌐 Politically Exposed Foreign Person

Someone who holds or held a major role in a foreign government:

• Head of state or government
• Minister, ambassador, military general
• Judge of top courts
• President of a state-owned company or bank
• Leader of political party

Reference: SOR/2002-184, s. 1(2)