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Beneficial ownership requirements : FINTRAC's compliance guidance

This guidance explains the beneficial ownership requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations.

As of October 1, 2025, you must consult Corporations Canada's database for corporations incorporated under the Canada Business Corporations Act that you have assessed pose a high risk of a money laundering or terrorist activity financing offence. If there is a material discrepancy between the beneficial ownership information and the individuals with significant control listed in the database, you must:

In this guidance

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1. Who must comply

This guidance applies to all reporting entities, except for title insurers.

2. Who beneficial owners are

Note: Canada's assessment of money laundering and terrorist financing risks, also referred to as the "National Risk Assessment", details the vulnerabilities posed by Corporations and other legal persons and arrangements. The concealment of beneficial ownership information is a technique used in money laundering and terrorist activity financing schemes. Identifying beneficial ownership removes the anonymity of the individuals (i.e. natural persons) behind the transactions and account activities, which is a key component of Canada's anti-money laundering and anti-terrorist financing regime.

Beneficial owners are the individuals who directly or indirectly own or control 25% or more of a corporation or an entity other than a corporation (such as a partnership).

In the case of a trust, they are the trustees, the known beneficiaries and the settlors of the trust.

If the trust is a widely held trust or a publicly traded trust, they are the trustees and all persons who own or control, directly or indirectly, 25% or more of the units of the trust.

Beneficial owners cannot be other corporations, trusts or other entities. They must be the individuals who are the owners or controllers of the entity.

In order to determine who the beneficial owners are, it may be necessary to search through as many layers of information as possible to determine the actual persons.

For example, the beneficial owners of a corporation that is owned by a trust would include all persons who own or control, directly or indirectly, 25% or more of the corporation through the trust, such as the trustees who manage the trust.

It is important to consider and review the names found on official documentation in order to confirm the accuracy of the beneficial ownership information. It may be necessary to search through many layers of information in order to confirm who are the beneficial owners, as the names found on official documentation may not always reflect the actual beneficial owners.

Legal references

3. When to obtain beneficial ownership information and confirm its accuracy

Note: By obtaining beneficial ownership information and confirming its accuracy, reporting entities are performing an important step to mitigate the risk of money laundering and terrorist activity financing, and ultimately, to protect the integrity of Canada's financial system.

You must obtain beneficial ownership information when you verify the identity of an entity in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations. For more information about when you are required to verify the identity of entities, see your sector's guidance on When to identify persons and entities.

The beneficial ownership information that you must obtain varies depending on whether the entity is a corporation, an entity other than a corporation (such as a partnership), a trust, or a widely held or publicly traded trust. The specific beneficial ownership information that you must obtain for each type of entity is detailed in section 5. What beneficial ownership information you need to obtain.

You must take reasonable measures to confirm the accuracy of the beneficial ownership information when you first obtain it and in the course of conducting ongoing monitoring of your business relationships.

Legal references

4. When and how to consult Corporations Canada’s database

In the case of a corporation incorporated under the Canada Business Corporations Act that you assessed poses a high risk of a money laundering or terrorist activity financing offence, you must consult Corporations Canada's database when you first determine there is a high risk and in the course of conducting ongoing monitoring of your high risk business relationships.

When consulting Corporations Canada's database, you must compare the information you obtained on the corporation to the individuals with significant control of the corporation listed in Corporations Canada's database and determine if there is a material discrepancy. More information on what is a material discrepancy is detailed in section 8. What a material discrepancy is and what to do if you identify one with Corporations Canada's database.

For more information on your requirements to assess your money laundering, terrorist activity financing and sanctions evasion risks in the course of your activities, refer to FINTRAC's Risk assessment guidance.

Consult the following resources by Corporations Canada:

Legal references

5. What beneficial ownership information you need to obtain

When you verify an entity's identity in accordance with the Regulations, you must obtain the following information about beneficial owners:

Corporations

Trusts

Widely held or publicly traded trusts

Entities other than corporations or trusts

In all cases, you must obtain information establishing the ownership, control and structure of the entity.

The Act and regulations do not prescribe the information that must be obtained to establish the ownership, control and structure of an entity, but you can obtain general information.

For example, the information establishing the ownership, control and structure of an entity could include

If you verify the identity of a not-for-profit organization, you must also determine if the entity is:

Legal references

6. How to obtain beneficial ownership information

To obtain beneficial ownership information, which includes information on the ownership, control and structure, you could have the entity provide it, either verbally or in writing, or you could search for publicly available information.

For example:

Collaboration between federal, provincial and territorial governments within Canada has led to harmonized amendments within most Canadian jurisdictions to require corporations to maintain accurate and up-to-date records of information on all beneficial owners, and to make them accessible upon request to law enforcement, tax authorities, and other relevant bodies. Such amendments have been made in all jurisdictions within Canada, except for Alberta, Northwest Territories and Nunavut. For more details, consult Annex 5: List of available federal and provincial resources on beneficial ownership.

7. How to confirm the accuracy of beneficial ownership information

You must take reasonable measures to confirm the accuracy of the beneficial ownership information that you obtain. These reasonable measures cannot be the same as the measures you used to obtain the information.

Your reasonable measures can include referring to official documentation or records, or consulting available provincial or federal registries.

It is also acceptable to have a client sign a document to confirm the accuracy of the beneficial ownership information you obtained, which includes information on ownership, control and structure. In this case, it is possible for one document to be used to satisfy the two steps—namely to obtain the information and to confirm its accuracy by means of the signature.

Other reasonable measures can include:

The reasonable measures that you take to confirm the accuracy of beneficial ownership information, which includes ownership, control, and structure information, should align with your risk assessment of money laundering or terrorist activity financing offences. The reasonable measures you take with entities assessed to pose a high risk must go further to help you understand and confirm the beneficial ownership, as well as establish the overall ownership, control, and structure of that entity. 

The reasonable measures that you take with entities that have a complex business structure must go further to ensure that you are able to understand and confirm the accuracy of beneficial ownership, which includes establishing the ownership, control and structure of that entity. This does not mean, however, that you need to consider or treat a complex entity as automatically posing a high risk. Your reasonable measures should be appropriate to the situation.

Legal references

Examples of official documentation or records to confirm the accuracy of the beneficial ownership information obtained:

Corporations or entities other than corporations or trusts

In the case of a corporation or other entity, you could refer to records such as, but not limited to:

Trusts, widely held or publicly traded trusts

In the case of a trust, you could confirm the accuracy of the information by reviewing the trust deed.

Not-for-profit organizations

As a best practice, you should also confirm whether a not-for-profit organization is a charity registered with the Canada Revenue Agency by consulting the charities listing on the Canada Revenue Agency website.

8. What a material discrepancy is and what to do if you identify one with Corporations Canada's database

A material discrepancy is a meaningful inconsistency between the beneficial ownership information of a corporation incorporated under the Canada Business Corporations Act and the individuals with significant control listed in Corporations Canada's database that could impact the proper identification, or conceal, the individuals that own or control a corporation.

A material discrepancy does not include a discrepancy that arises from:

When you identify a material discrepancy between the beneficial ownership information of a high-risk corporation incorporated under the Canada Business Corporations Act and the individuals with significant control listed in Corporations Canada's database, you must submit a Beneficial Ownership Discrepancy Report to Corporations Canada within 30 days after the day on which the discrepancy is identified.

Note: A material discrepancy that is resolved within 30 days after the day on which it is identified is not required to be reported.

For further clarity, a material discrepancy can be reported upon its identification without waiting for the 30 days to elapse. In addition, it is not a requirement to re-consult Corporations Canada's database within that timeframe to determine if the material discrepancy has been resolved. 

To submit a Beneficial Ownership Discrepancy Report, the corporation must have an active status in Corporations Canada's database.

For an example, consult Annex 2 - Example of a material discrepancy requiring a Beneficial Ownership Discrepancy Report

In the case of corporations incorporated under the Canada Business Corporations Act that you have assessed do not pose a high risk of a money laundering or terrorist activity financing offence, but for which you identify a material discrepancy, you have the option to voluntarily submit a Beneficial Ownership Discrepancy Report to Corporations Canada.

If you consulted Corporation Canada's database to confirm the accuracy of the beneficial ownership information you obtained, and if the identification of a material discrepancy prevents you from confirming the accuracy, you may take other reasonable measures that allow you to confirm its accuracy. When you cannot confirm the accuracy of the beneficial ownership information you obtained, you must apply prescribed measures as detailed in section 10. What to do if you cannot obtain beneficial ownership information or confirm its accuracy.

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9. How to submit a Beneficial Ownership Discrepancy Report

You must submit a Beneficial Ownership Discrepancy Report using the Beneficial Ownership Discrepancy Reporting application from your My ISED account.

For instructions on how to submit a Beneficial Ownership Discrepancy Report, consult Corporations Canada's reporting guidance Beneficial ownership discrepancy reporting

When submitting a Beneficial Ownership Discrepancy Report, you will be required to enter your reporting entity legal name and reporting entity number assigned by FINTRAC. Failure to provide the reporting entity legal name and reporting entity number will result in an invalid report.

If you do not have a reporting entity number assigned by FINTRAC, you must enroll to the FINTRAC Web Reporting System. To enroll, email your request to FINTRAC at F2R@fintrac-canafe.gc.ca

Corporations Canada will send a notice of acknowledgement of the Beneficial Ownership Discrepancy Report by email to the contact person who has filed the report and to the reporting entity email address, if provided.

Note: Notices of acknowledgement cannot be re-issued.

When you submit a Beneficial Ownership Discrepancy Report to Corporations Canada, you must keep a copy of all notice of acknowledgement received.

Retention: You must keep a copy of the notice of acknowledgement for 5 years from the day the record was created.

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10. What to do if you cannot obtain beneficial ownership information or confirm its accuracy

If you are unable to obtain the beneficial ownership information, to keep it up to date in the course of the ongoing monitoring of business relationships, or to confirm its accuracy, when it is first obtained, or during the course of ongoing monitoring then you must:

When you cannot obtain beneficial ownership information, keep it up to date or confirm its accuracy, such as when the ownership structure is too complex or opaque, it should be considered as part of your risk assessment of the client.

For more information, refer to:

How to verify the identity of an entity's chief executive officer or of the person who performs that function

The Regulations do not require that you verify the identity of the chief executive officer or of the person who performs that function in accordance with the prescribed methods. However, you could use one of the methods outlined in the Methods to verify the identity of persons and entities guidance to meet this obligation as your reasonable measure.

Additionally, there is no record keeping obligation if you have identified the chief executive officer or a person who performs that function using the prescribed methods to verify identity. However, during a FINTRAC examination, you could be asked to demonstrate the reasonable measures that you took to identify the chief executive officer or person who performs that function.

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11. Circumstances where you do not need to obtain beneficial ownership information and confirm its accuracy

You do not have to obtain beneficial ownership information and take reasonable measures to confirm its accuracy, including consulting Corporations Canada's database, in the following situations:

  1. For a group plan account held within a dividend or a distribution reinvestment plan. This includes plans that permits purchases of additional shares or units by the member with contributions other than the dividends or distributions paid by the plan sponsor, if the sponsor is an entity:
    • whose shares or units are traded on a Canadian stock exchange; and
    • that operates in a country that is a member of the Financial Action Task Force.
  2. If you are a financial entity, beneficial ownership requirements do not apply to your activities in respect of the processing of payments by credit card or prepaid payment product for a merchant.
  3. If you are a life insurance company, broker or agent, and you deal in reinsurance, beneficial ownership requirements do not apply to you for those dealings.

In all cases, the beneficial ownership requirements do not apply if you are not required to verify the identity of an entity under the Regulations because of a related exception. This is because your obligation to verify identity for a particular transaction, activity, or client does not apply in that circumstance. For more information, consult your sector-specific guidance on When to identify persons and entities.

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12. What to do if there are no beneficial owners

You may obtain information confirming that there is no individual who directly or indirectly owns or controls 25% or more of a corporation, a widely held or publicly traded trust, or an entity other than a corporation or trust. This is not the same thing as being unable to obtain the beneficial ownership information.  

If you determine that there is no individual who directly or indirectly owns or controls 25% or more of a corporation, a widely held or publicly traded trust, or an entity other than a corporation or trust, you must keep a record of the measures you took and the information you obtained in order to reach that conclusion. However, you are still required to obtain and take reasonable measures to confirm information about the ownership, control and structure of the entity.

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13. What beneficial ownership records you need to keep

You must keep a record of the beneficial ownership information you obtain and of the measures you take to confirm the accuracy of the information.

The measures that you take to confirm beneficial ownership information can be part of your overall policies and procedures, so a separate record may not be needed. You only need to keep an individual record of the specific measures you take to confirm the accuracy of beneficial ownership information in situations where the measures differ from those that are documented in your policies and procedures.

For a corporation, you must record:

For an example, consult Annex 1: Example of a record of beneficial ownership information for a corporation

For a trust, you must record:

For an example, consult Annex 4: Example of a record of beneficial ownership information for a trust (other than a widely held or publicly traded trust)

For a widely held or publicly traded trust, you must record:

For an entity other than a corporation or trust, you must record:

For an example, consult Annex 3: Example of a record of beneficial ownership information for an entity other than a corporation or a trust

If you verify the identity of a not-for-profit organization, you must also keep a record that indicates whether the entity is:

In situations where no individual directly or indirectly owns or controls 25% or more of a corporation, a widely held or publicly traded trust, or an entity other than a corporation or trust, you must keep a record of the measures you took to confirm the accuracy of the information, as well as the information you obtained in order to reach that conclusion. The date you took the measures should also be included as a best practice.

Retention: You must keep these records for at least 5 years from the day the last business transaction is conducted.

Legal references

Annex 1: Example of a record of beneficial ownership information for a corporation

Scenario:

ABC Canada Inc., a privately held corporation incorporated under the Canada Business Corporations Act, carries out a transaction or activity for which you have to verify its identity, triggering your beneficial ownership obligations. You learn that ABC Canada Inc. is owned by John Brown and Green Company Ltd. You discover that John owns 15% of the shares in the company (15 of the 100 total) and that Green Company Ltd. owns 85% of the shares (85 of 100 total). Since Green Company Ltd. owns and controls more than 25% of ABC Canada Inc., you need to find the beneficial owners, who cannot be a corporation or an entity. You inquire further and discover that Tina Grey owns 70% of Green Company Inc.'s shares and her two children, Alex and Lucy Grey, each own 15% respectively. Next, you learn that ABC Canada Inc.'s board of directors is made up of:

Diagram 1—Beneficial ownership information for a corporation

Flowchart of ABC Canada Inc. ownership and board of directors.
Text description of Diagram 1

The diagram shows the ownership and control structure of ABC Canada Inc. John Brown owns 15% of ABC Canada Inc. shares. Green Company Ltd. owns the remaining 85% of shares. Green Company Ltd. is owned by Tina Grey (70%), Alex Grey (15%), and Lucy Grey (15%). Because Tina Grey owns 70% of Green Company Ltd., she indirectly owns and controls more than 25% of the shares of ABC Canada Inc. The board of directors of ABC Canada Inc. consists of James Lochlin (chair), Jane Smith, Mark Jones, Tammy Maki, and Lisa Bailey.

In this example, you must record:

  1. The names of all directors of ABC Canada Inc.:
    • James Lochlin (chair);
    • Jane Smith;
    • Mark Jones;
    • Tammy Maki; and
    • Lisa Bailey.
  2. The names and addresses of all of the persons who directly or indirectly own or control 25% or more of the shares of ABC Canada Inc.:
    • The name and address of Tina Grey, who owns 70% of Green Company Ltd. Since Green Company Ltd. owns 85% of ABC Canada Inc.'s shares, and Tina owns 70% of Green Company Ltd.'s shares, Tina indirectly owns and controls more than 25% of the shares of ABC Canada Inc.
  3. The information establishing the ownership, control and structure of ABC Canada Inc., including:
    • the ownership of ABC Canada Inc. being shared between John Brown (15%) and Green Company Ltd. (85%);
    • the ownership of Green Company Ltd. being shared between Tina Grey (70%), Alex Grey (15%), and Lucy Grey (15%);
    • the control of ABC Canada Inc. significantly being held by Green Company Ltd. and specifically Tina Grey (who indirectly owns and controls more than 25% of ABC Canada Inc.'s shares);
    • the structure of ABC Canada Inc., including that it is a privately held corporation, and
    • other structure details about ABC Canada Inc., including the positions held by each director and any organization chart.
  4. The reasonable measures you took to confirm the accuracy of the information:
    • the steps you took as reasonable measures to confirm the accuracy of this information; and
    • any official documents obtained to support the measures you took.

Annex 2: Example of a material discrepancy requiring a Beneficial Ownership Discrepancy Report

Using the same scenario in Annex 1, you assessed, based on your risk assessment, that ABC Canada Inc. poses a high risk of a money laundering or terrorist activity financing offence.

As a result, you must also consult Corporations Canada's database to verify the beneficial ownership information you obtained.

Corporation Canada's database indicates 2 individuals with significant control of ABC Canada Inc., who both indirectly and jointly hold 25% or more of shares:

You had previously obtained the information that Tina Grey owns or controls 25% or more of ABC Canada Inc. The additional name "Johnson" is reasonably a minor variation in the name and is not considered a material discrepancy as it refers to the same individual.

Matthew Grey was not included as part of the beneficial ownership information you obtained on ABC Canada Inc. and is considered a material discrepancy.

If the material discrepancy is not resolved within 30 days, you must submit a Beneficial Ownership Discrepancy Report to Corporations Canada within 30 days after the day on which the discrepancy is identified.

In this example, you must also keep a record of the notice of acknowledgement from Corporations Canada you receive by email after you've successfully reported the material discrepancy.

Annex 3: Example of a record of beneficial ownership information for an entity other than a corporation or a trust

Scenario:

Rainbow Services, a partnership, carries out a transaction or activity for which you have to verify its identity, thus triggering your beneficial ownership obligations. You learn that Howard White and Betty Green are the two partners in this partnership. Betty is the general partner and is responsible for operating the day-to-day operations and Howard is the limited partner who has invested funds into the partnership. All decisions related to the partnership must be unanimous, and either partner can decide to end the partnership.

Diagram 2—Beneficial ownership information for an entity other than a corporation or a trust

Flowchart showing Rainbow Services partners and ownership
Text description of Diagram 2

The diagram shows the ownership and control structure of Rainbow Services. Howard White is a limited partner who owns and controls 50% of the partnership. Betty Green is a general partner who owns and controls the remaining 50% of the partnership.

In this example you must record:

  1. The names and addresses of all persons who directly or indirectly own or control 25% or more of Rainbow Services:
    • Howard and Betty's names and addresses, as the partners who equally own and control the partnership.
  2. The information establishing the ownership, control and structure of Rainbow Services, including that:
    • the ownership and control of Rainbow Services is held equally between Howard (50%) and Betty (50%), the structure of Rainbow Services, including that it is a partnership between Howard and Betty, and
    • any other structure details about Rainbow Services, including any organizational chart.
  3. The reasonable measures you took to confirm the accuracy of the information:
    • the steps you took as reasonable measures to confirm the accuracy of this information; and
    • any official documents obtained to support the measures you took, such as a copy of the partnership agreement.

Annex 4: Example of a record of beneficial ownership information for a trust (other than a widely held or publicly traded trust)

Scenario:

A trust carries out a transaction or activity for which you are required to verify its identity, triggering your beneficial ownership obligations. You learn that Robert Jones established a spousal trust for his wife Sue. He transferred assets into the trust and designated Joe Johnson as the trustee.

Diagram 3—Beneficial ownership information for a trust (other than a widely held or publicly traded trust)

Flowchart of spousal trust showing settlor, trustee, and beneficiary.
Text description of Diagram 3

The diagram shows the structure of a spousal trust. Robert Jones, the settlor, transfers income or assets into the spousal trust. Joe Johnson is the trustee who manages the trust. Upon the settlor’s death, the income or assets from the trust go to Sue Jones, the beneficiary.

In this example you must record:

  1. The names and addresses of all trustees, known beneficiaries and known settlors of the trust:
    • Robert's name and address, as he is the settlor;
    • Joe's name and address, as he is trustee; and
    • Sue's name and address, as she is the beneficiary.
  2. The information establishing the ownership, control and structure of the trust, including:
    • The beneficial ownership information is reflected in the information required to be obtained for the trust:
      • Robert is the settlor and can modify or revoke the terms of the trust;
      • Joe is the trustee and controls the assets in the trust; and
      • Sue, as the beneficiary, is the only person entitled to receive the assets or income from the trust.
    • The structure of the trust, including that it is a spousal trust.
  3. The reasonable measures you took to confirm the accuracy of the information:
    • the steps you took as reasonable measures to confirm the accuracy of this information; and
    • any official documents obtained to support the measures you took, such as the trust agreement.

Annex 5: List of available federal and provincial resources on beneficial ownership

Federal resources

Provincial and territorial resources

For assistance

If you have questions about this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

Date Modified: