Section C of the Corporate Identification Information Record (CIIR) assesses client risk. In this section, you are required to answer a few questions about the client, and the system will assign a risk score, to help you identify if this is a reasonable client to work with, or if the deal needs to be escalated to Zolo's Compliance team.
To complete section C of the CIIR, follow this guidance:
Review questions 1-17 in section C. For each question, respond "yes" or "no" based on the details of your client.
Do your due diligence: The answer to each question may not be immediately evident. You may need to ask your client for more information, perform an open internet search, or do further research to find the answers. Make sure to answer accurately. Any discrepancy in information will result in a rejected record.
Your answers to certain questions may require you to complete additional sections of the form. (E.g. if you answer "yes" to question 11 -"does the transaction involve a third party?", then you will also need to complete the third party declaration.) Ensure all information is consistent, and ensure that you provide sufficient detail for any questions requiring enhanced measures.
Once you have responded to all questions, click the "save and calculate" button. The system will analyze your responses and assign a risk score for the client.
The risk score should be below 10. If so, the client has been deemed low risk and you can move on to the next section of the form.
If the client risk score is above 10, you will see a warning to speak to the Compliance Officer. In this case, the client has been deemed high risk, and you should take these actions:
- Complete section D.2.3 - enhanced measures. In this section, provide notes about your client's situation. (For example, if you answer "yes" to question 12 - "does the transaction seem unusual in light of the client's occupation?" Then you must elaborate in section D.2.3.) When filling out D.2.3, be specific, concise, and clear. Failure to complete D.2.3 - enhanced measures for a high risk transaction will result in a rejected record.
- Determine if there is a material discrepancy in beneficial owner information. If the entity is a corporation incorporated under the Canada Business Corporations Act, consult Corporations Canada's database and compare the information you obtained on the corporation to the individuals with significant control of the corporation listed on the database. Determine if there is a material discrepancy.
- For high risk clients, you must also contact zolo_aml@questrade.com to discuss how to proceed with the transaction. If you determined the existence of a material discrepancy in step 2, inform the AML team of this discrepancy, so they can report it in accordance with the regulations under the PCMLTFA.