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Cheque cashers : FINTRAC's requirements

Effective April 1, 2025

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

Determine if FINTRAC's anti-money laundering and anti-terrorist financing requirements apply to your business and understand what you must do to comply.

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Who must comply

Persons or entities engaged in the business of providing cheque cashing services must fulfill obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations that apply to money services businesses and foreign money services businesses as applicable.

You are engaged in cheque cashing services when you offer to cash cheques for clients in exchange for funds.

Summary of requirements for cheque cashers

Persons or entities engaged in the business of cheque cashing services must fulfill the following requirements under the Act and associated Regulations.

Register as a money services business

Persons or entities engaged in the business of cheque cashing services must register as a money services business or a foreign money services business with FINTRAC.

Implement a compliance program

Money services businesses must implement a compliance program. A strong compliance program will form the basis of meeting your regulatory requirements.

Know your client

Money services businesses must verify the identity of persons and entities for certain activities and transactions, and carry out other customer due diligence activities.


When to verify the identity of persons and entities

Money services businesses must verify the identity of persons or entities who undertake prescribed activities and transactions.

Persons or entities engaged in the business of providing cheque cashing services must verify the identity of persons or entities when cashing one or more cheques that total $3,000 or more at the request of a person or entity.


Methods to verify the identity of persons and entities

Money services businesses must verify the identity of a person or entity using the methods detailed in the guidance.


Business relationship and ongoing monitoring requirements

Money services businesses enter into a business relationship with a client the second time they are required to verify the identity of that client or when they enter into a service agreement with a client that is an entity in Canada to provide a money services business service.

Once you enter into a business relationship, you must:

Further reading:


Beneficial ownership requirements

Money services businesses must obtain and take reasonable measures to confirm the accuracy of beneficial ownership information for entities.


Third party determination requirements

Money services businesses have third party determination requirements when they are required to submit certain reports and keep certain records.


Politically exposed persons and heads of international organizations requirements

Money services businesses are required to take reasonable measures to make politically exposed persons and heads of international organizations determinations for certain activities or transactions. If a money services business determines that a person is a politically exposed person or the head of an international organization then they have additional related requirements.

Report transactions

Money services businesses engaged in cheque cashing must submit the following reports to FINTRAC:


Listed Person or Entity Property Reports

Keep records

Money services businesses must keep certain records, including records related to transactions and client identification.

Persons or entities engaged in the business of providing cheque cashing services must keep a record of the following information when they cash one or more cheques that total $3,000 or more at the request of a person or entity:

Further reading:

Apply ministerial directives

Ministerial directive requirements apply to all reporting entity sectors unless otherwise specified in the directives.

FINTRAC assessment expectations

To ensure compliance with the Act and associated Regulations, FINTRAC is authorized to conduct compliance examinations to assess whether you are meeting your requirements under the law.

Areas of review can include:

To learn more about FINTRAC assessments, review the FINTRAC assessment manual.

Penalties for non-compliance

FINTRAC has the legislative authority to issue administrative monetary penalties to reporting entities that are found to be non-compliant with the Act and associated Regulations. For more information, see Penalties for non-compliance.

Glossary

The FINTRAC Guidance glossary includes terminology defined in the Act and associated Regulations, as well as terms used throughout the guidance. For more information, see FINTRAC's Guidance Glossary.

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