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As of October 1, 2025, reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) are subject to additional requirements, as amendments to the regulations under the PCMLTFA come into effect.
Highlights
- Reporting Material Discrepancies in Beneficial
Ownership Information. Reporting
entities must consult Corporations Canada's database for
federally incorporated corporations which they assessed as high
risk, and must file a “Beneficial Ownership Discrepancy
Report” with Corporations Canada when there is material
discrepancy between the reporting entity's internal records
and the beneficial ownership registry filings in the public
database. Reports must be made within 30 days of the discrepancy
being identified.Consult FINTRAC's beneficial ownership requirements
guidance for details on the reporting
process.
- Using and Verifying Agents or
Mandataries. Subject to certain requirements,
reporting entities are authorized to use an agent or a mandatary to
verify the identity of a corporation or an entity on their behalf.
Money services businesses and foreign money services business must
verify the eligibility of agents or mandataries that deliver money
services business services on their behalf, including through
criminal record checks.
- Listed Person or Entity Property Reporting. Reporting entities must submit a Listed Person or Entity Property Report to FINTRAC when required to make a disclosure under the Special Economic Measures Act or the Justice for Victims of Corrupt Officials Act to report the existence of property by or on behalf of a listed person or foreign national. This is in addition to existing requirements to submit such a report under the United Nations Act or the Criminal Code. Consult FINTRAC's listed person or entity property guidance for details on the reporting process.
- Verifying Identity of Unrepresented Parties in Real Estate Transactions. Real estate sales representatives and brokers must verify the identity of unrepresented parties, keep records, and make the associated third-party determination for such parties in real estate transactions.
- New Reporting Entity Designations. Title insurers and acquirer services in relation to private automated banking machines are now subject to compliance requirements under the PCMLTFA.
The content of this article does not constitute legal advice and should not be relied on in that way. Specific advice should be sought about your specific circumstances.
