Administrative monetary penalties: Changes following legislative amendments

Learn about the upcoming changes to administrative monetary penalties brought in by the Strengthening Canada’s Immigration System and Borders Act, and how the Financial Transactions and Reports Analysis Centre of Canada will implement the new approach under this updated legislative framework.

Upcoming changes to the administrative monetary penalties framework and policy

FINTRAC has had the legislative authority to issue administrative monetary penalties to reporting entities that are in non-compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations since December 30, 2008.

The Strengthening Canada’s Immigration System and Borders Act (Bill C-12), which received Royal Assent on March 26, 2026, introduces a new administrative monetary penalties framework under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

How FINTRAC is implementing the new framework

FINTRAC is updating its administrative monetary penalties policy and developing new guidance to reflect the changes introduced under the amendments. It will explain how penalties are administered under the new legislative framework.

For violations that occur after March 26, 2026, FINTRAC will apply the new legislative requirements.

FINTRAC will continue to use the existing administrative monetary penalties policy, penalty amounts, and processes for violations that occurred entirely before March 26, 2026.

FINTRAC continues to consult with reporting entities and industry stakeholders as the updated policy and guidance are developed.

Key changes to the administrative monetary penalties framework

The Strengthening Canada’s Immigration System and Borders Act introduces several enhancements to FINTRAC’s enforcement tools. These changes came into force on March 26, 2026, and apply to violations that occur after that date.

Under the new administrative monetary penalties framework, FINTRAC will have the authority to:

define prescribed violations and compliance order violations subject to penalties
apply increased maximum penalty amounts (up to 40 times current limits)
consider ability to pay as part of the criteria for determining a penalty amount
require mandatory compliance agreements for prescribed violations
introduce compliance orders as an additional enforcement tool

FINTRAC is updating its administrative monetary penalties policy to reflect these legislative changes. The updated policy will include:

guidance on compliance agreements and compliance orders
an updated approach to calculating penalties

Reporting entities that commit prescribed violations after March 26, 2026, will be required to enter into mandatory compliance agreements and may be subject to compliance orders.

FINTRAC’s supervisory assessments review past activities, and the penalties regime applied depends on both the examination period and the date when any violation occurred.

What reporting entities can expect

Reporting entities must continue to meet all obligations under the Act and Regulations.

FINTRAC will continue to assess compliance using the administrative monetary penalties policy that applies to the period under review. Because supervisory assessments examine past activity, the applicable policy is determined by whether the review period falls entirely before or after March 26, 2026.

Review periods that fall entirely before March 26, 2026, will continue to use the existing administrative monetary penalties policy.
Violations that occur on or after March 26, 2026, fall under the new legislative framework. These violations will be addressed in accordance with the amended Act and the updated administrative monetary penalties policy.

How FINTRAC will conduct assessments

FINTRAC will ensure that each examination is assessed using a single set of compliance expectations for the entire review period. This supports clarity and consistent supervisory outcomes.

To maintain this approach:

FINTRAC will scope examination review periods, so they fall entirely within one legislative framework
Examinations covering periods that fall entirely before March 26, 2026, will continue to apply the former administrative monetary penalties policy
Examinations covering periods that occur on or after March 26, 2026, will apply the new legislative framework

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