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I am acting for a developer of a new condominium project and am holding in trust the monies paid as deposits by the purchasers of the condo units. Do I have to identify the purchasers?

No. In that case the developer is not acting for or representing the purchasers with respect to the legal services you are providing to the developer. However, note that a real estate developer selling condominiums to the public may be a reporting entity to FINTRAC. As such, the real estate developer would have obligations to verify the purchasers’ identities, keep client information and source of funds records with respect to the purchasers and to take reasonable measures to determine if a purchaser is acting on behalf of a third party.