Client ID and “No Cash” Regulations
The Society has guidelines and processes (Regulations 4.12 and 4.13) to assist lawyers to ensure that they are not facilitating or otherwise assisting anyone to commit an illegal act, including money laundering and terrorist financing.
By adhering to these fundamental principles, lawyers help prevent crime and maintain public trust in the justice system.
The Federation of Law Societies developed these rules and all Canadian jurisdictions have adopted them. Regulation amendments to client identification and verification and the receipt of cash came into effect on January 1, 2020.
Sample Agent Agreement Instructions
We’ve created a sample Agent Agreement that may assist you in adapting to the Client Identification and Verification Regulations. This sample form is designed for use by lawyers retaining agents to verify the identity of a client, where the client is not instructing the lawyer in person.
This particular sample attempts to verify the identity of an individual/client by examining that person’s unexpired passport. Although the regulation does not require the agent to examine more than one piece of identification, depending on the circumstances of the file, you may want an agent to examine several pieces in addition to the passport, such as an unexpired driver’s licence or other government-issued identification.
Please modify this sample agreement to suit the circumstances of the matter or transaction.
If your client is signing other documents in the presence of the agent, such as an acknowledgment and direction authorizing you to electronically submit title documents for registration, you may wish to modify this agreement to set out any further instructions to the agent.
Before retaining the agent, it is prudent to confirm his/her fees for this service, in writing. We also recommend confirming these costs in writing with your client in advance, to minimize the risk of a misunderstanding about fees.
Client ID Documents & Resources
- Guidance on Politically Exposed Persons
- Source of Funds Guidance
- Return to Pre-Pandemic Client ID Rules and Review of Verification Options
- Risk Assessment and Compliance
- Quick Reference Guide on Potential Risks (Red Flags)
- The Federation of Law Societies of Canada Online Learning Program on “Anti-Money Laundering and Terrorist Financing in the Canadian Legal Profession”
- June 2021 Anti-Money Laundering/Client ID and Verification Webinar
- Client Identification and Verification Chart
- Clarification on remote Client ID Verification
- November 2023 – Federation of Law Societies of Canada’s updated guidance on Client ID and Verification Presentation (PDF)
- November 2023 – Federation of Law Societies of Canada’s updated guidance on Client ID and Verification Webinar
- Sample Agent Agreement (WORD)
- Client ID Overview Chart (PDF)
- Guidance for the Legal Profession: Your Professional Responsibility to Avoid Facilitating or Participating in Money Laundering and Terrorist Financing (PDF)
- Advisories to Address the Risks of Money Laundering & Terrorist Financing (PDF)
- Risk Assessment Case Studies (PDF)
- Guidance on Monitoring Obligations (PDF)
- Guidance on Using an Agent (PDF)
- Source of Funds Checklist (PDF)
- Verification of the Identity of an Organization Checklist (PDF)
- Client Verification Form- Organization (PDF)
- Client Verification Form – Individual (PDF)
- FAQ’s on the Client Identification and Verification Model Rule (PDF)
- Geographic Risk Information (PDF)
- Federation of Law Societies of Canada Releases Landmark Report on AML Regulation Ahead of FATF Review (March 2025)
- Federation of Law Societies of Canada Releases FATF Effectiveness Report (July 2025)
- Federation of Law Societies of Canada Notice on Title Insurers as Reporting Entities (PDF) (Sept 2025)