- with readers working within the Banking & Credit and Oil & Gas industries
- within Intellectual Property, Consumer Protection, Food, Drugs, Healthcare and Life Sciences topic(s)
- with Senior Company Executives, HR and Finance and Tax Executives
On August 6, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) released its updated supervisory framework and policies regarding monetary penalties. With respect to notices of violation, FINTRAC indicated it may issue them directly after certain assessment activities without the prior issuance of a separate finding letter. It is also specifically noted that any penalty reductions that may be granted are on a case-by-case basis. For more details, please see BLG's article "Changes to FINTRAC Supervision Model and Penalty Policy".
In addition, on August 22, FINTRAC referenced the federal 2025 Assessment of Money Laundering and Terrorist Financing Risks in Canada, known as the National Risk Assessment (NRA). The NRA provides an analysis of significant money laundering and terrorist financing threats and vulnerabilities in Canada. Registered advisers and dealers, who are subject to the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act), are expected to use the NRA when completing their business and relationship-based risk assessments. If your risk assessment does not refer to the latest NRA report, the firm may be deemed deficient in a FINTRAC audit. In practice for example, if a firm concludes that they are at a lower risk for money laundering, such firm will need to document consideration of the NRA guidance when drawing that conclusion.
Further updates were made in September, when FINTRAC announced new guidance for verification of client identity and noted that as of October 1, 2025, businesses subject to the Act can use an agent or a mandatary to verify the identity of a corporation or an entity on their behalf, and not just for verifying the identity of a person.
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.
