Language selection

Search

Video – FINTRAC: An introduction for reporting entities

This presentation is designed to provide an introduction to the Financial Transactions and Reports Analysis Centre of Canada.

Video

Video length: 36:40 minutes

Catalogue number: FD4-47/2025E-MP4

ISBN: 978-0-660-77104-5

Descriptive transcript of the video “Video – FINTRAC: An introduction for reporting entities”
Slide # Narration (audio) On screen description (text or image)

1

[Start of video]

Welcome to the webinar “FINTRAC: An Introduction for reporting entities”. This presentation is designed to provide an introduction to the Financial Transactions and Reports Analysis Centre of Canada, or FINTRAC.

We will discuss your role as a reporting entity under Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime.

Text on screen: FINTRAC: An introduction for reporting entities

2

This presentation covers several key topics:
FINTRAC’s mandate as Canada’s anti-money laundering and anti-terrorism financing regulator and financial intelligence unit.

Definitions of key concepts, including money laundering, terrorist financing, and sanctions evasion.

How FINTRAC ensures compliance and our supervisory approach.

Your obligations as reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, or the Act.

Enforcement activities used to encourage compliance.

And finally, key takeaways on your role in Canada’s Anti-Money Laundering and Anti-Terrorism Financing Regime.

Text on screen: Agenda

  1. FINTRAC’s mandate
  2. Money laundering, terrorist financing and sanctions evasion
  3. FINTRAC’s risk and supervisory frameworks
  4. Reporting entities: your compliance obligations
  5. Enforcement activities
  6. Key takeaways

3

FINTRAC serves as Canada’s financial intelligence unit and regulator under the Act.

Our mandate includes:

  • Detecting, preventing, and deterring money laundering and terrorist financing activities.
  • Receiving and analyzing financial transaction reports to generate actionable financial intelligence.
  • Ensuring compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act by overseeing reporting entities.

FINTRAC ensures the compliance of reporting entities (or businesses subject to the Act) and generate actionable financial intelligence for law enforcement and national security agencies.

FINTRAC acts independently from the police services, law enforcement agencies and other entities to which it discloses financial intelligence, while ensuring the protection of personal information under its control.

FINTRAC is headquartered in Ottawa, with regional offices located in Montreal, Toronto, and Vancouver. It reports to the Minister of Finance, who is in turn accountable to Parliament for the activities of the Centre.

Text on screen: FINTRAC’s mandate

To ensure the compliance of businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, and to generate actionable financial intelligence for police, law enforcement and national security agencies to assist in the investigation of money laundering and terrorist activity financing offences or threats to the security of Canada.

4

What is money laundering?

Money laundering disguises the source of money or assets derived from criminal activity. It is the process of taking money gained through illegal activities and making it appear legitimate.

Criminals use a variety of methods to do this, such as purchasing property, moving funds through multiple accounts, or using businesses to disguise the origin of their money.

While often linked to drug trafficking, it also involves crimes like fraud, corruption, and human trafficking.

The ultimate goal of money laundering is financial gain.

There are three stages:

  • Placement by introducing illicit funds into the financial system. For example, a deposit into an account.
  • Layering by creating complex transactions to obscure the trail. This stage may involve transactions such as sending or receiving transfers and purchasing drafts. Or transactions such as buying and selling of stocks, real property or other commodities.
  • Integration involves reintroducing funds into the economy with a perception of legitimacy.

The money laundering process is continuous, with illicit funds constantly being introduced into the financial system. It can often be difficult to detect without having appropriate controls in place.

Text on screen: Money laundering

  • Placement
  • Layering
  • Integration

Money laundering is the process used to disguise the source of money or assets derived from criminal activity.

5

Terrorist financing, on the other hand, is the use of funds, property, or other services to encourage, plan, assist, or engage in acts of terrorism.

Unlike money laundering, the goal of terrorist financing is not financial gain. Instead, it is to fund or facilitate terrorist activities.

There are two main differences that distinguish terrorist activity financing from money laundering.

First, the source of funds. While money laundering typically involves funds from illegal activities, terrorist financing can involve funds from legitimate sources, such as donations or personal savings.

Second, while the end goal for money laundering is to make illicit funds appear legitimate for personal gain, for terrorist financing, money is the means to an end, the goal is to use the funds to carry out terrorist activities.

Text on screen: Terrorist activity financing

Terrorist financing is the use of funds, property or other services to encourage, plan, assist, or engage in acts of terrorism, where the primary motivation is not financial gain.

6

Let’s talk about sanctions evasion, an important area of focus in Canada’s efforts to combat financial crime.

Sanctions evasion occurs when someone violates restrictions set by Canadian laws, such as the United Nations Act, the Special Economic Measures Act, or the Justice for Victims of Corrupt Foreign Officials Act.

For example, giving money or conducting business to help someone who is under sanctions would be considered a sanctions evasion offence.

Like many countries, Canada imposes sanctions on specific countries, individuals, and organizations. These sanctions restrict or prohibit certain trade, financial transactions, or other economic activities between Canadians—or persons in Canada—and the targeted entities.

Sanctions are a critical tool in Canada’s foreign policy. They help maintain and restore international peace and security, combat corruption, and promote respect for human rights.

As reporting entities, it’s important to be vigilant for signs of sanctions evasion. By identifying and reporting suspicious activities, you help Canada enforce its sanctions laws and uphold its commitments to global security and justice.

Text on screen: Sanctions evasion offence

A sanctions evasion offence means an offence arising from the contravention of a restriction or prohibition established by an order or regulation made under the United Nations Act, the Special Economic Measures Act, or the Justice for Victims of Corrupt Foreign Officials Act.

7

Global Affairs Canada is responsible for the administration of Canada’s sanctions under the United Nations Act, the Special Economic Measures Act, and the Justice for Victims of Corrupt Foreign Officials Act.

The RCMP and the Canada Border Services Agency enforce these statutes and associated regulations.

FINTRAC supports and ensures compliance with reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations which includes reporting on sanctions evasion and, since March 2, 2025, sanctioned property. FINTRAC also develops strategic intelligence products and discloses financial intelligence in support of law enforcement and the implementation of Canada’s sanctions regime.

Text on screen: Sanctions regime partners

Global affairs Canada

  • Responsible for the administration of Canada’s sanctions listings

RCMP and CBSA

  • Enforces statutes and associated regulations

FINTRAC

  • Supports and ensures compliance with reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations

8

We work with businesses to ensure they comply with the law. This includes issuing guidance to help you develop compliance programs, verify client identities, maintain records, and submit required reports. Our Supervision team provides guidance, conducts assessments, and promotes awareness to help businesses meet their obligations. We also maintain a public registry of money services businesses operating in Canada.

FINTRAC receives and analyzes financial transaction reports to uncover patterns and identify potential criminal activity. FINTRAC can disclose financial intelligence when appropriate thresholds are met. These include law enforcement at all levels, Canada’s security and border agencies, tax authorities, and securities regulators.

We also conduct research into financial intelligence and create strategic products that highlight trends, patterns, and vulnerabilities related to money laundering, terrorist financing, sanctions evasion and other threats to the security of Canada.

The safeguarding of personal information is critical to FINTRAC and clear principles for the protection of privacy are set out in its governing legislation, including strict limitations on the information that can be received and disclosed, clear requirements for maintaining and disposing of records, and a biennial audit of FINTRAC's protection of information by the Office of the Privacy Commissioner. These principles are reinforced by the Centre's own operational policies and security measures.

FINTRAC plays a vital role in protecting Canada’s financial system while balancing the need for privacy and security. Together, with your partnership as reporting entities, we can make a significant impact in the fight against financial crime.

Text on screen: FINTRAC’s roles and responsibilities

  • AML/ATF compliance
  • Financial intelligence unit
  • Maintain registry
  • Safeguard privacy
  • Cooperate with key partners
  • Research and awareness

9

It is important to note that FINTRAC does not lead or start an investigation. That is the role of law enforcement. FINTRAC’s role as a financial intelligence unit and federal regulator does not include freezing accounts, track transactions in real time, direct reporting entities to submit specific reports.

Text on screen: FINTRAC does not

FINTRAC does not…

  • Lead or start an investigation
  • Freeze accounts
  • Track transactions in real time
  • Direct reporting entities to submit specific reports

10

We are pleased to share an overview of FINTRAC's Supervisory framework which reflects our ongoing efforts to modernize and strengthen our approach to combatting money laundering, terrorist financing, and sanctions evasion.

The Supervisory framework is a comprehensive guide that aligns FINTRAC’s supervisory activities with its mandate. Our framework is dynamic and adaptable, designed to respond to the rapid changes of the digital age. It is built on three core components: Guiding principles, the Risk framework and strategic plan, and the Pillars of supervision.

Our supervisory culture is shaped by four guiding principles:

  1. Resources are allocated proportionally to the level of risk and complexity presented by reporting entities.
  2. Issues are identified early and addressed in a timely manner to prevent escalation.
  3. We provide clarity and predictability for reporting entities through guidance and engagement.
  4. Our approach is forward looking and anticipates emerging risks and evolves with the financial ecosystem.

The Supervisory framework is operationalized through three interconnected pillars:

  • We’re shifting to more targeted engagement, focusing on sector-specific guidance, tailored webinars, and direct conversations with high-risk industries. Transparency and dialogue remain central to this approach.
  • Monitoring is the cornerstone of our supervisory activities, focusing on assessing compliance. We use a risk-based approach, tailoring the intensity of monitoring activities to the risk profile of each reporting entity.
  • Monitoring tools include:
    • Examinations, which may be targeted or full-scope, and can assess both the technical soundness and effectiveness of compliance programs.
    • Action plans to address deficiencies and ensure corrective measures are implemented.
    • Mandatory reporting reviews to assess the quality and timeliness of submissions.

While we remain committed to supporting compliance, we are taking a firm stance on non-compliance. Serious or repeated deficiencies will lead to consequences, with enforcement decisions guided by factors such as compliance history, corrective actions, and harm caused.

The Risk framework and Supervisory framework are deeply interconnected. By embedding risk management into all supervisory activities, we ensure that our resources are focused where they are needed most.

This integration allows us to identify and address risks early, allocate resources efficiently, maintain alignment with international standards and best practices, commitment to continuous improvement.

FINTRAC recognizes that the financial ecosystem is constantly evolving. The Supervisory framework is dynamic and will continue to adapt to emerging risks, new technologies, and changes in the regulatory landscape.

The Risk framework is a cornerstone of FINTRAC’s approach, providing a structured methodology to assess and mitigate risks. Together with the Supervisory framework, it ensures that our activities are proactive, efficient, and aligned with our strategic priorities. Key elements include:

  • Early intervention to disrupt non-compliance risks.
  • Consistency in applying supervisory activities.
  • Transparency to build public trust and confidence in the financial system.
  • Continuous improvement through predictive risk assessment and management.

FINTRAC’s Risk framework and Supervisory framework is designed to address today’s challenges while preparing for the future. We are committed to working with you to strengthen Canada’s defences against financial crime.

Text on screen: FINTRAC’s supervisory framework

Guiding principles

  • Risk-based
  • Early intervention
  • Transparency
  • Forward-looking

Supervision pillars

  • Engaging
  • Monitoring
  • Enforcing

Risk framework

  • Compliance and ML/TF risks
  • Risk framework
  • Risk model
  • Risk rating
  • Supervisory planning

11

The National risk assessment is a comprehensive review of the most pressing money laundering and terrorist financing threats and vulnerabilities in Canada. It supports private sector businesses and non-governmental organizations to apply focused and proportionate measures to mitigate risks.

As part of reporting entities’ compliance program requirements under the Act and associated Regulations, reporting entities must conduct a risk assessment of their money laundering and terrorist financing risks.

FINTRAC expects that all reporting entities incorporate the national risk assessment into their own risk practices by using it as a foundational input to identify and understand inherent money laundering and terrorist financing risks relevant to their sector and operations.

You must also align your internal risk assessments with the findings to prioritize and tailor your due diligence, monitoring, and reporting measures accordingly.

This includes focusing enhanced scrutiny on high-risk areas highlighted by the National risk assessment and ensuring that ongoing updates to their risk assessments reflect changes in the national risk landscape. This approach will support effective resource allocation and regulatory compliance under the Act.

FINTRAC encourages all reporting entities to consult the risk assessment guidance and related tools, noting that FINTRAC does not prescribe how a risk assessment should be conducted.

Text on screen: National risk assessment

Purpose:

  • Identifies new and evolving vulnerabilities to money laundering and terrorism financing in the Canadian economy
  • Informs Canada’s AML/ATF strategy including regulatory and operational responses

Outcomes:

  • Regulatory amendments
  • Stronger compliance expectations
  • Expansion of covered sectors and activities

12

Criminals, including money launderers and terrorist financiers, can be attracted to Canada as a result of inherent vulnerabilities associated with Canada’s geography, demographics, stable open economy, accessible financial system and well-developed international trading system.

The scale of your operations, and the cash-intensive nature of your clientele, allow for you to be used in obscuring the origin of funds and provide anonymity for your clientele. Money laundering, terrorist financing, and sanctions evasion present significant challenges across industries, as criminals continuously exploit vulnerabilities through complex transactions, cash-intensive businesses, and third-party relationships. As a reporting entity, your role is vital in mitigating these risks. By implementing strong compliance measures, conducting thorough risk assessments, and submitting accurate and timely suspicious transaction reports (STRs), you help protect Canada’s financial system and disrupt criminal networks. This shared responsibility is not just a legal obligation—it is a collective effort to safeguard the integrity of our economy and protect Canadians from the harms of financial crime.

Being compliant provides important measures for detecting and deterring criminals and terrorists from operating within Canada.

Text on screen: Your role in the fight against illicit financing

Detection:
Compliance with the broader legislative and regulatory obligations provides important measures for deterring criminals and terrorists from operating within Canada’s legitimate economy.

Deterrence:
Compliance with the legislation also ensures that we are all contributing to the fight against ML and TF. For example, simply implementing “know your client” measures is a means of deterrence as it eliminates the anonymity of the transaction.

13

FINTRAC regulates and supervises specific business sectors, known as reporting entities. These sectors include financial institutions, securities dealers, real estate brokers, casinos, and more.

The following slides outlines key compliance obligations that apply to reporting entities.

Text on screen: Who must comply: regulated businesses

Business sectors

  • Accountants
  • Agents of the Crown
  • Armoured cars
  • British Columbia notaries
  • Casinos
  • Cheque Cashers
  • Dealers in precious metals and precious stones
  • Factors
  • Financing or leasing entities
  • Financial entities
  • Life insurance
  • Mortgage
  • MSBs and FMSBs
  • Acquirers ABMs
  • Real estate
  • Securities dealers
  • Title insurers

14

As a reporting entity, you have legal obligations under the Act and associated Regulations. These include:

  • Establishing and maintaining a strong compliance program.
  • Knowing your client, including verifying the identity of clients or entities and carrying out other due diligence activities.
  • Keeping records related to transactions and client identification.
  • Registering with FINTRAC if you are a Money Service Business.
  • Reporting certain financial transactions that meet monetary or suspicious activity thresholds, or, those suspected to be related to terrorist property or sanctions evasion.
  • Reporting entities are also required to comply with applicable ministerial directives, which are designed to impose countermeasures for transactions involving high-risk jurisdictions.           

There are other requirements under each of these primary obligations that are specific to each sector. The next few slides cover a summary of a few of the key compliance requirements.

Text on screen: Overview of compliance obligations

  1. Compliance program
  2. Know your client (KYC)
  3. Reporting to FINTRAC
  4. Record keeping
  5. Register with FINTRAC as an MSB/FMSB
    (only applicable to MSB/FMSB)
  6. Ministerial Directives

15

All reporting entities must have a compliance program comprised of the following elements:

A Compliance officer who is responsible for implementing and overseeing the compliance program.

They should be in a position of authority, have sufficient knowledge of the business, and understand its money laundering, terrorist financing and sanctions evasion risks.

As a best practice, the compliance officer should not be involved in the receipt, transfer or payment of funds.

Your business’ compliance policies and procedures help guide the decisions and actions of your business to meet its legal requirements. Your policies and procedures should be documented, tailored to your business, and kept up to date.

You must assess and document the risks your business faces. This includes analyzing your clients, products, geographic locations, and delivery methods and how they may be vulnerable to money laundering, terrorist financing or sanctions evasion.
We’ll present the risk assessment process in more detail shortly.

Your business must also have a compliance training program and a plan in place for its employees. Your employees must be trained on compliance obligations, tailored to their roles. For example, front-line staff may need training on identifying suspicious transactions.

Your training plan should identify those who are receiving the training, topics covered, the delivery method and training frequency. The training you deliver should also be documented.

If you’re a sole proprietor with no employees, you’re not required to have a training program.

Every two years, you must review the effectiveness of your compliance program to ensure it meets current regulatory requirements.

This review can be conducted internally or by an external auditor, and findings should be documented along with any corrective measures taken to rectify deficiencies.

Text on screen: 1. Compliance program

  • Compliance officer
  • Policies and procedures
  • Risk assessment
  • Training program
  • Effectiveness review

16

Risk assessments are often overlooked, but they are a critical part of your compliance program.

A thorough risk assessment helps you understand the money laundering and terrorist financing risks your business faces and implement controls to mitigate those risks.

When developing or updating your risk assessment, you must consider and review Canada’s National Risk Assessment: it provides a comprehensive analysis of money laundering and terrorist financing risks in Canada by identifying key sectors and products vulnerable to these threats. By consulting the National Risk Assessment, businesses subject to the Act can gain a deeper understanding of these risks, focus their resources on vulnerable areas, implement effective strategies or controls to mitigate those risks, and ensure the integrity of their operations and reputation.

Text on screen: What is risk?

RISK
Threats: Individuals, organized crime groups, predicate offences, terrorist organizations

Inherent Vulnerabilities: Properties of a sector, service, customer base, delivery channel, jurisdiction, etc.

Consequences: Societal, economic, or governmental harm done

17

You must address the following 5 factors in your risk assessment:

Your clients and business relationships, including their activity patterns and geographic locations. For example, who are your clients? Do you serve a specific category of clients? Do any of your clients have a connection to a country that has weak money laundering and terrorist financing controls?

Your products, services and delivery channels. Do you offer brokering, lending and administrative services or do you just offer one type of service? Do you meet your clients in person or virtually? Do you use agents?

The geographic locations where you conduct your activities. Do you have a single office in a small town, or do you have multiple offices in major cities across Canada?

New developments or technologies. Are you using new technologies like facial recognition software for identification purposes or to auto-approve applications? If so, what is the risk level compared to meeting the client in person?

Any other relevant factors affecting your business. This can be anything else that might affect your risk level such as employee turnover or other industry rules and regulations that you follow.

You must assess each factor and provide a risk rating such as high, medium or low. Regardless of the level you determine, you need to have written rationale that supports the risk level for the 5 prescribed factors.

Text on screen: Risk assessment

Risk assessment factors
Written rationale that supports the risk level

  • Your clients and business relationships
  • Your products, services and delivery channels
  • Geographic location(s) where you conduct your activities
  • New developments or new technologies
  • Any other relevant factors affecting your business

18

Verifying the identity of clients is a cornerstone of compliance. It removes the anonymity behind financial transactions, helps you to know your clients; and to understand and assess any risks that may be associated to their transactions or activities.

There are five methods you can use to verify the identity of a person:

  • Government-issued photo identification that is authentic, valid and current (for example a passport or driver’s license)
  • Credit file method: Using information from a Canadian credit bureau
  • Dual process method (like referring to two separate reliable sources, such as a utility bill and a bank statement)
  • Confirming identity through an Affiliate or member (note that this is only for financial entities, life insurance and securities dealers sectors)
  • Reliance method (or, relying on measures previously taken by another regulated business for which you have a written agreement in place)

Text on screen: 2. Know your client: verifying the identity of a person

There are five methods you can use to verify the identity of a person.

  1. Government-issued photo identification method
  2. Credit file method
  3. Dual process method
  4. Affiliate or member method
  5. Reliance method

19

When it comes to verifying the identify of an entity, there are three methods:

  • Confirmation of existence method (for incorporated businesses, such as referring to a certificate of incorporation)
  • Reliance method (similar to individuals, this involves relying on another regulated business under a written agreement)
  • Simplified identification method (for entities who are deemed to meet specific low-risk criteria)

Each of these methods to verify the identity of persons or entities are explained in greater detail in our guidance on our website.

Depending on what sector you belong to, there will be different triggering situations for when you need to verify the identity of a person or entity.

Text on screen: Know your client: verifying the identity of an Entity

There are three methods you can use to verify the identity of an entity

  • Confirmation of existence method
  • Reliance method
  • Simplified identification method

20

In addition to verifying identity, you also have other requirements relating to knowing your client:

Third party determination means taking reasonable measures to determine whether a third party is involved in a transaction.

You must Identify individuals who own or control 25% or more of a corporation or trust. This is critical because criminals often conceal beneficial ownership to obscure illicit activity. Business relationships mean establishing when a business relationship begins and monitoring client activities over time. Business relationship criteria varies by sector and depends on the activities and transactions that a client conducts with you.

Ongoing monitoring is a process you must implement to review all the information and activities of your business relationships, in order to:

  • Detect any suspicious transactions;
  • Keep client identification; information and records up to date;
  • Reassess the level of risk associated with your client's transactions and activities; and
  • Determine whether transactions or activities are consistent with the client information you obtained and the risk assessment of the client.

Depending on your sector, you have certain requirements relating to the identification of domestic and foreign Politically Exposed Persons, Heads of International Organizations, and their family members and close associates.

The access, influence and control that they have can make them vulnerable to corruption and be the potential targets of criminals who could exploit their status and use them--knowingly or unknowingly—to carry out money laundering or terrorist activity financing, or sanctions evasion offences.

Text on screen: Know your client: additional requirements

  1. Third party determination
  2. Beneficial ownership
  3. Business relationships
  4. Ongoing monitoring
  5. Politically exposed persons and heads of international organizations

21

Financial transaction reports are critical to FINTRAC’s ability to develop actionable financial intelligence that supports law enforcement and national security investigations.

All reporting entities must submit the following transaction reports when they meet certain criteria:

  • Suspicious transaction reports, STRs, are some of the most unique and valuable reports a reporting entity can submit to FINTRAC.
  • You must report a suspicious transaction report when there are reasonable grounds to suspect that a transaction in the course of your activities is related to the commission or the attempted commission of a money laundering, terrorist financing or sanctions evasion offence.
  • There is no monetary threshold for suspicious transaction reports, but the quality of the information you provide is critical: STRs allow for an expansion on the descriptive details surrounding a transaction, and your assessment of what you are seeing through your business interactions and activities.
  • Details like nicknames, secondary names, IP addresses, email addresses, virtual currency transaction details, and relationships can help FINTRAC uncover broader connections.
  • STRs can reveal trends, patterns, and vulnerabilities in Canada’s financial system and spark investigations into crimes like human trafficking, child sexual exploitation, drug trafficking, fraud, and terrorism.
  • Without STRs, FINTRAC would not be able to disclose such compelling and actionable financial intelligence to law enforcement bodies. 

You must submit a Listed Person and Entity Property Report if you are in possession or control of property owned or controlled by a listed person or entity under the Criminal Code, the United Nations Act, or other sanctions legislation.

Examples of property include:

  • Cash
  • Monetary instruments (for example, cheques, bank drafts or money orders)
  • Casino products and tokens
  • Virtual currency
  • Accounts (for example, personal or business accounts, Registered Retirement Savings Plans, Tax-Free Savings Accounts
  • Prepaid payment products and prepaid payment product accounts
  • Securities (for example, stocks, bonds or mutual funds)
  • Jewelry, precious metals or precious stones
  • Real estate, including an instrument that gives title or right to a property (for example, a deed)
  • Insurance policies

These reports must also be disclosed to the RCMP and CSIS.

Large cash transaction reports or LCTRs must be submitted:

  • If you receive cash in the amount of $10,000 CAD or more, or the equivalent in foreign currency, in the course of a single transaction.
  • This applies even if the transaction is completed in multiple installments within a 24- hour period, as the total cash received must be aggregated.

This 24-hour rule applies if two or more cash transactions total $10,000 or more within 24 hours and involve the same person, entity, or beneficiary.

Similar to Large Cash Transaction Reports, large virtual currency transaction reports or LVCTRs must be submitted to FINTRAC when you receive virtual currency in an amount equivalent to $10,000 CAD or more, in a single transaction, or accordance with the 24-hour rule
This includes cryptocurrencies such as Bitcoin, Ethereum, or any other form of virtual currency. Virtual currencies are increasingly being used for legitimate purposes, but they are also attractive to criminals due to their pseudonymous nature and potential for cross-border transfers.

Financial entities, casinos, and money services businesses, must also submit electronic fund transfer reports or EFTRs to FINTRAC when:

  • They are the final recipient of an international EFT of $10,000 CAD or more in a single transaction (the 24-hour rule may apply). or
  • They initiate, at the request of a person or entity, an international EFT of $10,000 CAD or more in a single transaction (the 24-hour rule may apply).

Casino disbursement reports or CDRs:

  • Casinos must submit CDRs for disbursements of $10,000 or more in a single transaction.

For detailed guidance on reporting requirements, visit FINTRAC’s website.

Text on screen: 3. Reporting to FINTRAC

  • Suspicious Transaction Report (STR)
  • Listed Person and Entity Property Report (LPEPR)
  • Large Cash Transaction Report (LCTR)
  • Large Virtual Currency Transaction Report (LVCTR)
  • Electronic funds transfer reports (EFTR)
  • Casino disbursement reports (CDR)

22

Record-keeping is essential for compliance. It ensures you can submit timely and complete reports and provide information to FINTRAC during examinations or investigations.

You must keep records of:

  • Client identification information.
  • Details of financial transactions that meet reporting thresholds.
  • Records related to your compliance program, such as policies, risk assessments, and training.

Records must be accessible and provided to FINTRAC within 30 days if requested. Sector-specific record-keeping requirements may apply. For example, real estate brokers may need to keep records of unrepresented party transactions. To learn more about sector-specific record keeping requirements, please review the record keeping guidance applicable to your sector on our website.

Text on screen: 4. Record keeping requirements

Every reporting entity must keep specific records according to the Act and associated Regulations

Records may include:

  • Reporting records – a copy of every report sent to FINTRAC
  • Transaction records
  • Client identification records

Note: Please ensure you are aware of all the types of records that your reporting entity sector must keep.

23

If you are a money services business (MSB) or a foreign money services business (FMSB), you must register with FINTRAC before operating in Canada.

Let’s break down the key steps:
Responding to clarification requests:

  • FINTRAC may request additional information during the registration process. You must respond within 30 days.

Keep your registration updated:

  • If there are changes to your business, such as a new address or contact person, you must update FINTRAC within 30 days.

Renew your registration:

  • Registration is valid for two years. Be sure to renew before it expires.

Cancel your registration:

  • If you stop offering MSB services, you must cancel your registration.

For more information, visit the MSB section of our website.

Text on screen: 5. Registering with FINTRAC

REGISTER:
Money services businesses and foreign money services businesses must register with FINTRAC

RESPOND:
You must respond to clarification requests from FINTRAC

UPDATE:
You must keep your registration information up to date and inform FINTRAC of any changes

RENEW:
You must renew your registration before it expires after 2 years

CANCEL:
If your business ceases to meet the definition of a Money services business and foreign money services business, you must cancel your registration

24

The Minister of Finance may issue directives that contain countermeasures or restrictions for businesses when they engage in transactions with certain foreign jurisdictions.

These authorities allow the Minister of Finance to take steps to protect Canada’s financial system from foreign jurisdictions and foreign entities that are considered to present high risks for facilitating money laundering and terrorist financing.

FINTRAC monitors and assesses compliance with these directives, and failure to comply with a directive could result in a penalty.

FINTRAC has published guidance related to the Ministerial Directive on financial transactions associated with Russia (issued on February 24, 2024), the Islamic Republic of Iran (issued on July 25, 2020) and the Ministerial Directive on the Democratic People’s Republic of Korea issued on (December 9, 2017).

For more information, please refer to the guidance on our website.

Text on screen: 6. Ministerial directives

  • Issued by the Minister of Finance
  • Contain countermeasures and restrictions for designated foreign jurisdictions
  • All reporting entities are subject to ministerial directives requirements
  • FINTRAC monitors and assesses compliance with these directives

25

The success of Canada's Anti-Money Laundering and Anti-Terrorist Financing Regime depends on the concrete application of the regulatory measures we discussed above. 

In the normal course of our compliance activities, we identify instances of non-compliance with the Act and associated Regulations. We assess the severity of each non-compliance issue by understanding both the extent and the root cause of the non-compliance. Each non-compliance issue is assessed for its adverse impact on FINTRAC's mandate and on the achievement of the objectives of the Act.

Following the completion of an assessment activity, and depending on the extent of the non-compliance identified, FINTRAC may decide:

  • to take no further action
  • to conduct follow-up assessment activities
  • to issue an administrative monetary penalty to encourage a change in behaviour
  • to disclose relevant information to law enforcement for investigation and prosecution of non-compliance offences under the Act and associated Regulations

FINTRAC may issue an administrative monetary penalty and serve a notice of violation when it has reasonable grounds to believe that a reporting entity has violated a requirement of the Act and associated Regulations.

Administrative monetary penalties (AMPs) are fines issued by FINTRAC. They may be issued in cases of serious or repeated non-compliance. We consider the penalty to be effective when the amount is both proportional to the harm done and prompts a change in behaviour toward future compliance. These amounts keep into consideration the type and extent of the violations, the harm done, and the circumstances of each case.

Non-compliance disclosures are disclosed to law enforcement in cases of extensive non-compliance when FINTRAC suspects on reasonable grounds that the information would be relevant to investigating or prosecuting non-compliance offences under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Text on screen: Enforcement activities

Administrative monetary penalty:
A violation under the Act (civil)

  • Part 4.1 of the Act
  • Fines issued by FINTRAC
  • Persons: Max $100,000 per instance
  • Entities: Max $500,000 per instance
  • Publicly named once imposed by FINTRAC

Non-compliance disclosure:
An offence under the Act (criminal)

  • Part 5 of the Act
  • Charges laid by law enforcement
  • Summary: Max. $250,000 or $1,000,000 and/or 2 years prison
  • Conviction: Max. $500,000 or $2,000,000 and/or 5 years prison

26

The purpose of FINTRAC's administrative monetary penalties program is to encourage future compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, and to promote a change in behaviour. The administrative monetary penalties program supports FINTRAC's mandate by providing a measured and proportionate response to particular instances of non-compliance. FINTRAC is committed to working with reporting entities to help them achieve compliance.

The process involves:

  • Issuing a Notice of Violation, which outlines the penalty amount and the factors considered.
  • The reporting entity has 30 days to pay the penalty or make representations to FINTRAC’s Director and CEO.
  • If no action is taken, the penalty is upheld, and FINTRAC publishes the business’ name, the violation, and the penalty amount.

AMPs are designed to be proportional, encourage compliance, and deter future violations.

Text on screen: Supervision – Enforcement: administrative monetary penalty

  1. Non-compliance identified
  2. Notice of violation
  3. Notice of decision
  4. Appeals, publication and collection

27

As reporting entities, you are the frontline defense against money laundering, terrorist financing, and sanctions evasion and help protect Canada’s financial system and national security.

By identifying and reporting suspicious activities, you provide valuable information that helps law enforcement and national security agencies protect Canadians.
Your diligence and compliance with reporting requirements make a real difference in safeguarding Canada’s financial system.
Your compliance efforts in maintaining strong compliance programs and submitting reports directly support the detection and prevention of crimes such as fraud, human trafficking, child exploitation, terrorism and more—all of which have serious impacts on people in our communities, our national security and the integrity of our nation’s economy.

It’s essential to stay informed about emerging risks and vulnerabilities in your sector.

Criminals constantly adapt their methods to exploit businesses for money laundering, terrorist financing, and sanctions evasion.
Expanding our collective knowledge of compliance obligations and evolving threats is critical to strengthening Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime.

At FINTRAC, we support reporting entities in meeting their compliance obligations by providing:

  • Guidance publications on our website
  • Assistance with MSB registration
  • Support for developing training materials and modules, and
  • Collaboration and partnership

Combating money laundering and terrorist financing requires a shared commitment from all stakeholders—across sectors, both domestic and international.

By working together with reporting entities, law enforcement, and other organizations, we can better identify threats, uncover financial connections, and provide actionable intelligence to advance investigations.

Text on screen: Your role in Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime

  • Compliance helps deter, detect and prevent money laundering, terrorist financing and sanctions evasion
  • Continuous learning and awareness building
  • Collaboration and partnership

28

Thank you for your attention and for your commitment to protecting Canada’s financial system. Your role as reporting entities is vital to the success of Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime. We encourage you to stay informed by visiting FINTRAC’s website regularly for updates and guidance.

If you have any questions, please don’t hesitate to reach out to us at guidelines-lignesdirectrices@fintrac-canafe.gc.ca

[End of video]

Text on screen: Thank you!

Please visit our website for more guidance:
https://fintrac-canafe.canada.ca

Please send your questions to:
guidelines-lignesdirectrices@fintrac-canafe.gc.ca

Related links

Date Modified: