The new guide from the Investment Industry Regulatory Organization of Canada states that it is often at the account-opening stage that dealers can identify suspicious activity or suspicious transactions. Some examples:

> A client exhibits an unusual concern regarding the firm’s compliance with government reporting requirements — particularly with respect to client identity, type of business and assets — or is reluctant to reveal any information.

> A client wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with his or her stated business strategy.

> A client — or a person publicly associated with the client — has a questionable background or is the subject of news reports indicating possible violations.

> A client appears to be acting as the agent for another entity but declines, evades or is reluctant to provide any information in response to questions about that entity.

> A client has difficulty describing the nature of his or her business or lacks general knowledge of the industry.

> A client attempts to dissuade the IIROC firm from following its normal account-opening procedures or attempts to have transactions executed immediately. — PAUL BRENT