Amendments to the Client Identification and Verification rule now permit you to choose any suitable person to act as an agent. Previously, agents had to be individuals in occupations who could provide an attestation respecting compliance with the verification requirements. The rule also provided a list of those occupations. As the attestation requirement has been removed, along with the list, you may now choose any appropriate individual to act as your agent. You should use your professional judgment to choose someone who is suitable.

Keep in mind that the responsibility for verifying an individual’s identity is yours, even when using an agent. You should always be the one who chooses the agent; don’t rely on your client or the individual whose identity is being verified to find the agent.

You should ensure that the agent is reputable, reliable, accountable, and, where feasible, familiar with anti-money laundering due diligence requirements. If you do not know a suitable candidate, you should check with the regulator for the legal profession in the jurisdiction where the individual is located.