- with Finance and Tax Executives
- with readers working within the Securities & Investment industries
As always, registrants subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Act) should review the federal Minister of Finance's updated directives, including the recent Ministerial Directive on the Islamic Republic of Iran, effective as of November 15, 2025. The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has issued guidance related to this directive, which includes the following:
- Affected registrants must report every financial transaction to or from Iran, regardless of amount and those transactions must be treated as high-risk transactions;
- The identity of every client must be identified if they request or benefit from such a transaction;
- Registrants must exercise customer due diligence with respect to such transactions, and look for risks of a sanction's evasion offence (e.g. the source of the funds, purpose of the transaction and ascertaining the beneficial ownership/control of any entity requesting or benefiting from the transaction); and
- Keep records of any such transaction, regardless of amount.
It is important that your firm's policies and procedures:
- Include information on how the firm becomes aware of ministerial directives and how it will respond;
- Describe how the firm will determine that a transaction originates from or is bound for Iran (or any other country that is the subject of a similar Ministerial Directive); and
- The specific mitigation measures the firm will take upon making this determination.
FINTRAC considers that failure to comply with measures outlined in a ministerial directive is a very serious offence and failure to comply may result in a penalty in accordance with the penalty regulations related to the Act.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
