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On April 16, 2026, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) published information on the new initiatives and updates it is implementing as a result of recent or upcoming legislative amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations (AMP Regulations). The amendments to the PCMLTFA and the AMP Regulations were introduced in the Budget 2025 Implementation Act and the Strengthening Canada’s Immigration System and Borders Act, both of which received Royal Assent on March 26, 2026.
Administrative Monetary Penalties (AMPs)
There will be changes to FINTRAC’s AMP framework in light of the amendments to the AMP Regulations, including changes to:
- significantly increase the maximum amount of AMPs that may be imposed for prescribed violations, up to:
- $40,000 in the case of a minor violation (up from $1,000);
- $4,000,000 in the case of a serious violation (up from $100,000); and
- $20,000,000 in the case of a very serious violation (up from $500,000);
- introduce ability to pay as part of the criteria for determining an AMP amount;
- introduce the use of compliance agreements in all cases where an AMP is imposed;
- introduce compliance orders as a new enforcement tool;
- designate the contravention of a compliance order as a new violation under the PCMLTFA; and
- elevate certain compliance program violations from serious to very serious.
FINTRAC noted that it is currently updating its AMP policy and developing accompanying guidance that will outline the principles, processes, and criteria used to administer penalties.
Compliance Program and KYC Requirements
The amendments to the PCMLTFA now require that reporting entities have a compliance program that meets the higher standard of being “reasonably designed, risk-based and effective” (in addition to the existing requirement to have an AML compliance program that is “intended to ensure their compliance” with the AML regime). Failure to meet this requirement is designated as a “very serious” violation.
The amendments also clarify requirements related to the prohibition of anonymous accounts and introduce a definition of anonymous client.
FINTRAC noted that it will be updating its guidance to outline its expectations for these requirements.
Universal Enrolment with FINTRAC
Coming into force in line with regulations to be developed and published at a later date, the amendments to the PCMLTFA will require businesses subject to the PCMLTFA (that are not already required to do so) to enroll with FINTRAC.
Information Sharing
Other amendments effective March 26, 2026 make the Director and CEO of FINTRAC a member of the Financial Institutions Supervisory Committee and enable FINTRAC to (i) exchange supervisory information on federally regulated financial institutions with other members of the Financial Institutions Supervisory Committee and (ii) provide financial intelligence disclosures to the Commissioner of Canada Elections.
Stablecoin Issuers
The Budget 2025 Implementation Act enacts the Stablecoin Act, which establishes regulatory requirements for stablecoin issuers, and which will come into force on a day to be fixed by order of the Governor in Council. The coming into force of the Stablecoin Act will be dependent on the development and publication of associated regulations. Stablecoin issuers will be required to register with FINTRAC as money services businesses dealing in virtual currency. To that end, FINTRAC will update its existing guidance for money services businesses to account for stablecoin issuers.
Looking Ahead
FINTRAC has noted that it will continue to provide information to assist businesses subject to the PCMLTFA in complying with their expanded obligations resulting from these recent and upcoming amendments to the AML Regime.
Fasken’s Financial Services Group is actively monitoring regulatory developments in this area.
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.
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