The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) updated its guidance for businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) as regulations come into force on October 1, 2025.
Money services businesses and foreign money services businesses
As of October 1, 2025, money services businesses and foreign money services businesses must verify the eligibility of agents or mandataries that delivers money services business services on their behalf, including through criminal record checks.
For more information, refer to FINTRAC’s guidance: Money services businesses and Register your money services business (MSB) or your foreign money services business (FMSB).
Beneficial ownership requirements and Beneficial Ownership Discrepancy Report
As of October 1, 2025, businesses subject to the Act must consult Corporations Canada’s database for corporations incorporated under the Canada Business Corporations Act they assessed as high risk. They are also required to submit a Beneficial Ownership Discrepancy Report to Corporations Canada when there is a material discrepancy between the beneficial ownership information they obtained and the individuals with significant control information available in the database.
For more information, refer to FINTRAC’s guidance: Beneficial ownership requirements.
Listed Person or Entity Property Report
As of October 1, 2025, businesses subject to the Act must submit a Listed Person or Entity Property Report to FINTRAC when they are required to make a disclosure under the Special Economic Measures Act or the Justice for Victims of Corrupt Officials Act to disclose the existence of property in their possession or control that is owned, held or controlled by or on behalf of a listed person or foreign national.
This is in addition to the requirement, since March 2, 2025, to submit a Listed Person or Entity Property Report to FINTRAC when they are required to make a disclosure under the United Nations Act or the Criminal Code.
For more information, refer to FINTRAC’s guidance: Reporting listed person or entity property to FINTRAC.
Other changes in force
As a reminder, as of October 1, 2025:
• Title insurers and acquirer services in relation to private automated banking machines must fulfill obligations under the Act and associated Regulations
• Businesses subject to the Act can use an agent or a mandatary to verify the identity of a corporation or an entity on their behalf
• Real estate sales representatives and brokers must verify the identity of unrepresented parties, keep records and make the associated third party determination for these parties in real estate transactions
For an overview of all the important changes and updates, consult: Modernization and upcoming changes impacting reporting entities.
For questions, please contact FINTRAC by telephone at 1-866-346-8722 (toll-free) or by email at guidelines-lignesdirectrices@
