As of January 22, 2024, corporations registered under the Canada Business Corporations Act (“CBCA”) must maintain and provide a record of individuals with significant control (“ISC”) to Corporations Canada. 

An ISC is an individual who owns or controls a corporation, meeting specific criteria described below:

• Owns, controls, or directs 25% or more of shares individually or in concert with others;
• Exercises control in fact over the corporation without share ownership;
• A combination of the above factors.
  
  

Section 73(1)(c) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”) has been amended to require reporting entities to validate whether beneficial ownership of corporations registered under the CBCA information received is in accordance with Corporations Canada’s registry (registry).

As such, the following policy must be adhered to:

1.    Identity verification and beneficial ownership information:

1. Verify if the entity is CBCA registered via the Corporations Canada registry;
2. If the entity is not CBCA registered, proceed per existing procedures;
3. If the entity is CBCA registered, proceed to step 2.
   
   

1. Validate the information in the entity’s ISC section.

Note: If the ISC section of Investia’s Complementary Form is empty (Section 1 – Corporation), please ensure the client updates the registry prior to opening the account.

3.    Comparison of information provided with the registry:

1. Confirm consistency between entity-provided details and registry information;
2. If the information is consistent, proceed per existing procedures;
3. If the information in this section is different, proceed to step 4.
   
   

4.    Request for additional beneficial ownership information:

1. Representative must ask the entity for supplementary details if discrepancies exist and ensure Investia’s “Complementary Form – Corporation, Formal Trust and Other Entities” is completed in full.
2. A discrepancy in information may be deemed sufficient to continue the business relationship if the ownership structure has changed since the time the information was filed on the Corporations Canada registry. In this case, the entity would need to provide you with proof of the change in ownership and ensure to update the registry.
3. Failure to provide this information may necessitate discontinuation of the business relationship.