Canada implements amendments to the PCMLTFA anti-money laundering and anti-terrorist financing regime

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has published information on the implementation of legislative amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). These amendments, enacted through the Strengthening Canada’s Immigration System and Borders Act and the Budget 2025 Implementation Act, received Royal Assent on March 26, 2026, introducing expanded compliance obligations, enhanced information sharing powers, and a strengthened enforcement regime.

Strengthening Canada’s Immigration System and Borders Act

The Strengthening Canada’s Immigration System and Borders Act introduces the following amendments to the PCMLTFA and associated Regulations:

• introducing a new administrative monetary penalties (AMP) framework;
  
  
• requiring compliance programs to be reasonably designed, risk-based, and effective;

• clarifying requirements related to the prohibition of anonymous accounts and introducing a definition of anonymous client;
• The categories of financial institutions, businesses, professionals, governments, and related persons under section 5 of the PCMLTFA are prohibited from opening an anonymous account or an account for an anonymous client.
• A client is “anonymous” if the person or entity cannot verify the identity of the client in accordance with the Regulations or if the client’s name is obviously fictitious.

• requiring all businesses subject to the PCMLTFA (other than those already required to register) to enroll with FINTRAC;
   
• enabling FINTRAC to provide financial intelligence disclosures to the Commissioner of Canada Elections; and
   

• enabling FINTRAC to exchange supervisory information on federally regulated financial institutions with other members of the Financial Institutions Supervisory Committee.     

The new AMP framework will come into force on March 26, 2026, in accordance with the applicable transitional provisions, and will significantly expand FINTRAC’s enforcement toolkit. The framework increases the maximum amount of AMPs that may be imposed for prescribed violations, introduces the ability to pay as an explicit criterion in determining penalty amounts, and requires the use of compliance agreements in all cases where an AMP is imposed. It also introduces compliance orders as a new enforcement tool, designates the contravention of a compliance order as a distinct violation under the PCMLTFA, and elevates certain compliance program violations from serious to very serious. In parallel, FINTRAC is updating its AMP policy and developing accompanying guidance to outline the principles, processes, and criteria that will govern the administration of penalties under the new framework.

Notably, perhaps the most structurally significant change introduced by the Strengthening Canada’s Immigration System and Borders Act is the creation of a comprehensive enrolment regime for reporting entities. Under new sections 11.4001 through 11.4015 of the PCMLTFA, every person or entity referred to in section 5, with limited exceptions, must enroll with FINTRAC. Enrolment requires a formal application to FINTRAC, periodic renewal, ongoing obligations to report changes to application information, and timely responses to clarification requests from FINTRAC. FINTRAC must establish and maintain a publicly accessible roll of enrolled entities. FINTRAC is empowered to deny or revoke enrolment where a person or entity has committed a violation and failed to pay the resulting penalty. Failure to enroll has also been added to the list of criminal offences under section 74 of the PCMLTFA. These enrolment provisions come into force on a day to be fixed by order of the Governor in Council.

Budget 2025 Implementation Act

The Budget 2025 Implementation Act amends the PCMLTFA as a consequence of the new Stablecoin Act's enactment. The Stablecoin Act imposes duties on persons that create stablecoins and make them available for purchase, directly or indirectly, by persons in Canada. Once in force through future regulatory amendments, stablecoin issuers will be required to register with FINTRAC as money services businesses. Section 5 of the Stablecoin Act provides that a stablecoin issuer is deemed to be "a person that is engaged in the business of dealing in virtual currencies for the purposes of subparagraphs 5(h)(iv) and (h.1)(iv) of the [PCMLTFA]." This effectively brings stablecoin issuers within the ambit of the PCMLTFA's anti-money laundering and anti-terrorist financing regime as reporting entities (REs).

The following amendments will come into force on a date determined by the Governor in Council:

• enhancing the authority of the Director of FINTRAC to disclose information to the Minister of Finance (or an officer of the Department of Finance) for purposes related to national security or safeguarding the integrity of Canada's financial system. This amendment ensures that FINTRAC can share relevant intelligence with the Minister of Finance when the Minister is carrying out supervisory and national security functions under the new stablecoin regulatory framework; and
  
  
• broadening FINTRAC's ability to share compliance-related information with the Bank of Canada. The changes allow disclosure of compliance information deemed relevant to the Bank's supervisory functions under both the Retail Payment Activities Act and the Stablecoin Act. Additionally, they limit the use of such information to ensure it is only employed for these specific purposes or for preparatory planning related to unimplemented provisions of the Stablecoin Act.

Conclusion

As Canada’s regulatory landscape continues to evolve and in light of FINTRAC’s increasing AMPs, REs must stay informed in order to navigate growing compliance complexities. With multiple amendments coming into force on different dates, FINTRAC has indicated that further guidance will be provided to assist businesses subject to the PCMLTFA in complying with their obligations relating to these amendments as they come into force. 

If you are concerned that your business may be impacted, contact a member of our Financial Services or Compliance team for assistance.