Canadian MSBs are supervised by FINTRAC under the PCMLTFA and its regulations. This pack sets ClearSet's onboarding evidence requirements to match what a FINTRAC examiner looks for on an entity file: confirmed legal existence from an official registry, beneficial owners identified to the 25 percent threshold, and the ownership and control structure recorded rather than asserted.
UBO threshold set to 25 percent.
FINTRAC defines a beneficial owner as an individual who directly or indirectly owns or controls 25 percent or more of the shares of a corporation, or of an entity other than a corporation. The ultimate beneficial owner cannot be another entity: it must be a natural person.
Cited to official guidance rather than a specific subsection.
ownership_chain and control are required facts for entity customers.
Confirming beneficial ownership is not only naming the owners: reporting entities must obtain and record the ownership, control and structure of the entity, and take reasonable measures to confirm that information is accurate.
Cited to official guidance rather than a specific subsection.
legal_existence must be evidenced by an official registry document.
An entity's existence is confirmed from a record such as a certificate of incorporation or an annual filing made with a provincial or federal registry, not from a document the customer produced themselves.
Cited to official guidance rather than a specific subsection.
registered_address evidence expires after 90 days.
A registry extract or address proof that predates the relationship by months does not evidence where the business is today. Ninety days is the working freshness window ClearSet applies unless an org widens it.
Cited to official guidance rather than a specific subsection.
Iran, North Korea and Myanmar are prohibited jurisdictions.
Canada issues Ministerial Directives requiring countermeasures for transactions connected to jurisdictions FATF has identified as high risk and subject to a call for action. Treating them as prohibited at onboarding is the conservative reading.
Cited to official guidance rather than a specific subsection.
This pack is a starting point, not legal advice. It sets ClearSet’s onboarding evidence requirements to a defensible baseline for the regime, and every rule stays editable in your settings with each change recorded in the audit trail.
Start with the FINTRAC MSB pack already applied.
Pick it during setup and your first assessment runs against these rules. Change any of them afterwards; every change is recorded.