Effective January 1, 2022, amendments to the Law Society of
Ontario's Anti-Money Laundering measures, will require law
firms to ask their clients for additional information from time to
time. The obligation to identify clients and to obtain basic
contact and employment information has been with us for some time.
Law firms have been required to verify this client information by
reviewing identification documents where the nature of the retainer
involves the receipt, payment or transfer of funds and there is no
applicable exemption.
The amendments to the LSO by-laws have eliminated some of the
exemptions and have imposed additional requirements to obtain
information about the source of funds being used in the retainer,
an active requirement to monitor the retainer to ensure no
indications of fraud, and that instructions received are consistent
with the retainer.
