FINTRAC updates guidance language on voluntary self‑declaration of non‑compliance

FINTRAC has amended its guidance on Voluntary Self‑Declaration of Non‑Compliance (VSDONC) and the implications for reporting entities. The key shift is that the earlier assurance that qualifying VSDONCs would be treated “without enforcement” has been removed, altering how and when to use VSDONCs.

Under the prior guidance, when a VSDONC was not a repeated instance and not made after notice of examination, FINTRAC stated it “will work with the entity to resolve the issue and will not propose enforcement actions, such as an administrative monetary penalty related to the submission.”

In the updated guidance, FINTRAC still indicates it will work with entities to resolve issues where the declaration is not a repeated instance and not made after notice of assessment activity, but it now states that it “will carefully consider the specific circumstances of each case when deciding the appropriate course of action,” with no express statement that enforcement will not be proposed.

The change to the website appears to have taken place on October 9, 2025, although there is no indication by FINTRAC that this change was made on a specific date.

Practical effect of the changes

VSDONCs remain a useful tool for promoting compliance and resolving issues, but they are no longer explicitly “without enforcement.” Entities should continue to avoid using VSDONCs for repeat non‑compliance and should not file them after being notified of an upcoming examination or assessment activity. A concrete remediation plan with timelines should accompany any submission.

What to include in a VSDONC

• Name of reporting entity and contact details of the individual submitting the VSDONC;
• Reporting Issues:the number of reports impacted, type, and the time period during which the issues occurred, as well as the reason why the reports were not submitted, were late, or incorrect, and other related details;
• Other Issues: the period of time during which the issues occurred, the reason for their occurrence; and
• Remediation Plan: A plan to resolve the issues and submit all outstanding (or incorrect/incomplete) reports, including measures and timelines for corrective action.

For other submission details or assistance, see FINTRAC’s guidance or contact a member of our Financial Services or Compliance team.