Canada · AML

The PCMLTFA: what FINTRAC requires of accountants, real estate and BC notaries

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act sets Canada's AML rules, and FINTRAC supervises them. Bill C-12 raised maximum penalties 40-fold from 26 March 2026 and will require every reporting entity to enrol.

In brief
  • Accountants, real estate brokers, sales representatives and developers, and BC notaries are reporting entities under the PCMLTFA when they carry out specified activities.
  • Bill C-12 received Royal assent on 26 March 2026 (S.C. 2026, c. 4). The maximum penalty for a prescribed violation rose from C$100,000 to C$4,000,000 for a person and from C$500,000 to C$20,000,000 for an entity.
  • Every reporting entity that pays an administrative monetary penalty must now enter a compliance agreement with FINTRAC.
  • Universal enrolment with FINTRAC is in the Act but not yet in force. Its timing depends on regulations to be published in the Canada Gazette, Part II.
  • Title insurers and acquirers of private automated banking machines became reporting entities on 1 October 2025.

Canada · AML/CTF · FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) · Reviewed 5 Nov 2026

Industries: Accounting, Real estate, Precious metals and stones, Trust and company services, Conveyancing

What it is

What it is

The PCMLTFA and its regulations set out who must run an anti-money laundering program in Canada and what that program must do. Businesses listed in section 5 of the Act are reporting entities. FINTRAC receives their reports, examines their compliance and imposes administrative monetary penalties when they fall short.

Part 9 of Bill C-12, the Strengthening Canada's Immigration System and Borders Act, made the largest changes in years. According to the Library of Parliament summary, it raises the maximum penalty per prescribed violation to C$4,000,000 for a person and C$20,000,000 for an entity. Cumulative penalties in a notice can reach the greater of those amounts and 3% of gross global income or revenue. It also adds compliance orders, makes compliance agreements mandatory, extends the account-opening ban to clients with obviously fictitious names, and requires all reporting entities to enrol with FINTRAC.

FINTRAC says the new penalty framework applies from 26 March 2026. From the same date, compliance programs must be reasonably designed, risk-based and effective, and a new definition of anonymous client applies. Enrolment comes later, on a day set by order once regulations are made.

Who it applies to

Who it applies to

Professional firms are covered by activity, so the trigger matters more than the job title. FINTRAC describes these triggers:

  • Accountants and accounting firms that, for a client, receive or pay funds or virtual currency, buy or sell securities, real property or business assets or entities, or transfer funds, virtual currency or securities. Audit, review and compilation engagements are excluded.
  • Real estate brokers and sales representatives acting as agent for a buyer or seller. Property management only is not covered.
  • Real estate developers once they pass FINTRAC's sales tests, such as selling five or more new houses or condominium units to the public in a calendar year.
  • BC notaries and notary corporations carrying out the same three activities as accountants, other than for professional fees, disbursements or bail.
  • Banks and other financial entities, securities dealers, life insurers, money services businesses, mortgage businesses, casinos, title insurers and the other listed sectors.

Lawyers do not appear on FINTRAC's list of reporting entities. Employees of a reporting entity generally carry no obligations of their own, except suspicious transaction reporting.

The obligations

What you have to do

FINTRAC groups the duties into a compliance program, know your client, reporting and record keeping. Each is matched below to the kind of work that meets it.

  1. Run a compliance program

    Appoint a compliance officer, keep written policies, train staff and review the program's effectiveness every two years. From 26 March 2026 it must be reasonably designed, risk-based and effective.

    Program, reviewed every two years
  2. Assess your risk

    Document a risk assessment of your clients, services, delivery channels and geography. It sets where you apply enhanced measures.

  3. Verify identity with a prescribed method

    Use one of FINTRAC's methods: government-issued photo ID, credit file, dual-process, affiliate or member, reliance, or an agent. Photo ID can be checked remotely if you authenticate the document and match the person to it, for example with a selfie compared by facial recognition.

  4. Confirm beneficial ownership and third parties

    For entity clients, obtain beneficial ownership information and take reasonable measures to confirm it, and make third party determinations. Since 1 October 2025 real estate brokers and representatives must also verify unrepresented parties.

  5. Identify PEPs and check sanctions

    Make reasonable efforts to identify politically exposed persons and heads of international organizations. Report property of listed persons and suspected sanctions evasion.

  6. Monitor business relationships

    Keep watching established business relationships and update client information as risk changes.

  7. Report and keep records

    File suspicious transaction, large cash and large virtual currency transaction reports with FINTRAC, follow the 24-hour rule, and keep client identification and transaction records.

    Filed with FINTRAC
Commonly misread

What firms get wrong

Bill C-12 changed the stakes quickly, and some of its parts are not yet in force.

Penalties are what they were last year.

For violations committed on or after 26 March 2026, the Bill C-12 framework applies, with maximums 40 times higher. Violations before that date are assessed under the old framework (FINTRAC).

We must enrol with FINTRAC now.

Universal enrolment is enacted but commences on a day fixed by order, in line with regulations to be published in the Canada Gazette, Part II. Money services businesses already register. Watch FINTRAC's modernization page.

A video call with the client counts as photo ID verification.

FINTRAC says it is not enough to only view a person on a video call. You must authenticate the document, confirm it is valid and current, and confirm the name and photo belong to the person.

Paying the penalty closes the matter.

Every entity that pays a penalty must enter a compliance agreement. Refusing or breaching one leads to a public compliance order, and breaching that order carries a penalty of up to the greater of C$5,000,000 and 3% for a person, or C$30,000,000 and 3% for an entity (Library of Parliament).

Key dates

What happens when

  1. In force

    Title insurers and acquirers of private ABMs become reporting entities; real estate brokers and representatives must verify unrepresented parties Source

  2. In force

    Bill C-12 receives Royal assent (S.C. 2026, c. 4) Source

  3. In force

    New penalty framework, mandatory compliance agreements and compliance orders apply; program and anonymous client changes take effect Source

  4. Not yet setCommencing

    Universal enrolment with FINTRAC for all reporting entities Source

    Not yet confirmed. We will update this when the date is set.

Questions

Questions people ask

What is the PCMLTFA?

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act is Canada's anti-money laundering law. With its regulations, it requires reporting entities to run a compliance program, know their clients, report certain transactions to FINTRAC and keep records.

What does FINTRAC do?

FINTRAC receives reports from reporting entities, examines their compliance and issues administrative monetary penalties. Since Bill C-12 it can also issue compliance orders, and it will run a public roll of enrolled reporting entities once enrolment starts.

Do accountants have to comply with FINTRAC?

Yes, when they receive or pay funds, buy or sell securities, property or business assets, or transfer funds or securities for a client. Audit, review and compilation work does not trigger the obligations, and giving advice is different from giving instructions.

What are FINTRAC's identity verification requirements?

Use a prescribed method: government-issued photo ID, credit file, dual-process, affiliate or member, reliance, or an agent under a written agreement. Remote photo ID checks need document authentication and a match between the person and the photo. See types of identity verification.

What are the FINTRAC penalties after Bill C-12?

Up to C$4,000,000 per prescribed violation for a person and C$20,000,000 for an entity, with cumulative caps linked to 3% of gross global income or revenue. These apply to violations from 26 March 2026.

Does a realtor need to verify the other side of the deal?

Since 1 October 2025, real estate brokers and sales representatives must verify the identity of unrepresented parties, keep an information record and make the related third party determination.

Do we have to enrol with FINTRAC?

Not yet. Bill C-12 requires all reporting entities to enrol and renew periodically, but that part starts on a date set by order once regulations are published.

Where StackGo fits

Where StackGo fits

StackGo is compliance middleware. IdentityCheck can carry the identity, screening, intake and risk assessment steps in a FINTRAC compliance program. Your policies still have to describe how each step meets the prescribed method, and the PCMLTFA does not require any particular product.

What IdentityCheck covers today
  • Biometric identity verification: a photo of a government ID document plus a live selfie with liveness, covering 12,500 document types from 230+ countries and territories.
  • PEP, sanctions and adverse media screening, with ongoing monitoring of screened clients.
  • Intake forms, including multi-entity forms that collect each person and entity on a structure for beneficial ownership records.
  • Risk assessment forms with scoring and enhanced due diligence steps.
  • Two-way integrations with Xero Practice Manager, Xero, Karbon and HubSpot; Salesforce via Zapier. By default no personal details are written back, only a link to the result plus the outcome and status.
What it does not do
  • It does not file suspicious transaction, large cash or any other report with FINTRAC, and it does not enrol you with FINTRAC.
  • It does not run the credit file or dual-process methods.
  • No transaction monitoring and no legal advice.

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