Third-Party Determination

Clarify third-party relationships in financial transactions with precision. Stay compliant, reduce exposure, and fulfill your FINTRAC reporting obligations with confidence.

Why Third-Party Determination?

When conducting financial transactions, it's essential to determine if a third party is involved—someone other than the client providing instructions or funding. This third-party identification is a key compliance requirement under Canadian anti-money laundering (AML) regulations.

Our Third-Party Determination service helps your organization consistently capture, assess, and document third-party involvement in accordance with FINTRAC expectations. Automate due diligence, standardize decision-making, and minimize compliance risks.

Who Is It For?

Financial institutions and banks
Credit unions and cooperative lenders
Money services businesses (MSBs)
Securities dealers and portfolio managers
Real estate brokers and developers
Legal firms, accountants, and DNFBPs

These organizations routinely face complex transaction chains, and misidentifying third-party involvement could result in regulatory penalties or inadvertent facilitation of illicit activity.

Key Benefits

Clear Risk Identification
Uncover when a third party is truly involved—no more guesswork.
Streamlined Data Collection
Prompt clients to provide required details at the right time.
Audit-Ready Records
Maintain structured logs of third-party information for FINTRAC reviews.
Minimized Exposure
Identify red flags early by understanding who is really behind the transaction.

Use Cases

A client conducts a wire transfer on behalf of a relative living abroad.
An account is opened in one name, but instructions consistently come from another individual.
A business transaction is funded from an unrelated personal account.
A real estate buyer claims to be the client, but the funds originate from a different party.
An employee processes a transaction for their employer without clear documentation.

How It Works

Flag transactions or onboarding events requiring third-party determination.
Prompt client to disclose if another person is giving instructions or providing funds.
Collect required third-party information (name, address, date of birth, occupation).
Log rationale and response in audit trail.
Store and update the third-party relationship in the client profile.
Submit relevant data to FINTRAC when required.

Features

Automated Triggers
Identify when third-party determination is required based on transaction type or onboarding logic.
Dynamic Data Capture
Use configurable forms to collect third-party information inline with client workflows.
Decision Logging
Track who made the determination, when, and why—ensuring full transparency.
Integrated Compliance Flags
Raise alerts if third-party involvement suggests higher ML/TF risk.
Audit-Ready Reporting
Export structured third-party data with just a click for internal or external reviews.

Frequently Asked Questions


What is considered a third party?
A third party is an individual or entity who gives instructions or funds a transaction, even though they are not the direct client.

Is a company executive a third party in company transactions?
Not necessarily. If acting within their official capacity and clearly associated, they may not be considered a third party. However, clarity and documentation are essential.

Do I have to collect third-party info every time?
Only when a third party is involved. If the client confirms no third-party involvement, record the rationale and date.

What if the client refuses to provide third-party information?
You should not complete the transaction and must assess if a suspicious transaction report is required.

How long must I retain third-party records?
Typically five years after the last transaction or account closure, as per FINTRAC guidelines.

Getting Started

Third-party involvement can indicate hidden risk. Our system ensures you're never caught off guard—and always compliant.

Fill out the short contact form below or choose another convenient way to reach us. Our team is here to listen, answer your questions, and help you get compliant — fast.

Contact Us

Thank you for your interest. You have multiple options to connect with us.