How often are reporting entities required to update client identification information for high-risk clients?
A review of the assessment of the money laundering and terrorist financing risks for your business is required every two years, for the purpose of testing its effectiveness. Therefore, FINTRAC recommends that high-risk client identification information be reviewed and updated at least every two years to help make the risk assessment relevant, as risk levels may change over time. This does not mean that you have to identify these clients again. You can ask them if their information is up-to-date when they come in or when you send them written correspondence.
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