Now in effect: Regulatory updates impacting reporting entities under Canada’s AML regime

Several amendments to Canada's Anti-Money Laundering and Anti-Terrorist Financing regime took effect on October 1, 2025. These amendments modify obligations for reporting entities (REs) subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations.

Regulations that came into force on October 1, 2025:

• enhance corporate beneficial ownership transparency by requiring the reporting of material discrepancies;
• strengthen the registration framework for money services businesses;
• allow agents or mandataries to be used when verifying the identity of corporations and other entities;
• create an obligation for real estate sales representatives and brokers to verify the identity of unrepresented parties, keep an information record and make the associated third-party determination for these parties in real estate transactions;
• create obligations for acquirers of private automated banking machines and title insurers; and
• require the reporting of sanctioned property related information under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act.

This Finance Alert discusses these changes and key takeaways for REs.

Beneficial ownership: Discrepancy reporting

Effective October 1, 2025, all REs, with the exception of title insurers, must consult the Corporations Canada's database for corporations incorporated under the Canada Business Corporations Act that they have assessed pose a high risk of a money laundering or terrorist activity financing offence. In cases where there is a material discrepancy between the beneficial ownership information and the individuals with significant control listed in the database, these REs must:

• report the discrepancy to Corporations Canada within 30 days, and
• keep a copy of the notice of acknowledgement received from Corporations Canada.

A material discrepancy is a meaningful inconsistency between the beneficial ownership information of a corporation incorporated under the Canada Business Corporations Act and the individuals with significant control listed in Corporations Canada's database that could impact the proper identification or conceal the individuals that own or control a corporation. For more information, FINTRAC’s website offers guidance on recognizing such discrepancies and appropriate reporting steps.

Money services businesses: Engaging agents or mandataries

Money services businesses (MSBs) may now use agents or mandataries to verify the identity of corporations and other entities, provided the MSB:

• determines and documents the agent’s or mandatary’s eligibility before engagement, and
• reconfirms eligibility within 30 days after the second anniversary of the most recent verification, provided the agent or mandatary is still engaged.

Agents or mandataries engaged after October 1, 2025, must meet these requirements before engagement. Those already engaged before that date must comply by October 1, 2027. Non-compliance can result in significant fines and/or imprisonment.

Real estate sales representatives and brokers: Verifying identity of unrepresented parties

Real estate brokers and sales representatives acting as agents or mandataries in purchases and sales must now:

• verify the identity of unrepresented parties (i.e., any party that takes part in a purchase or sale of real estate and is not represented by a real estate broker or sales representative) participating in the transaction;
• maintain an information record on unrepresented parties; and
• conduct the associated third-party determination for these parties in real estate transactions.

FINTRAC’s guidance outlines exceptions to these requirements that potentially implicated REs should review carefully.

Acquirers of private automated banking machines (ABMs) and title insurers: New compliance obligations

Entities engaged in the business or providing acquirer services in relation to a private ABM and title insurers are now subject to compliance requirements under the Act and associated Regulations:

• An acquirer is an entity that connects a private ABM to a payment card network to facilitate transactions.
• A private ABM includes any automated banking machine that is not owned or operated by a bank as defined in section 2 of the Bank Act, by an association regulated by the Cooperative Credit Associations Act or by a cooperative credit society, a savings and credit union or a caisse populaire regulated by a provincial Act.
• A title insurer is a person or entity that is engaged in the business of providing title insurance, as defined in the schedule to the Insurance Companies Act.

FINTRAC will conduct compliance examinations to assess adherence and has legislative authority to issue administrative monetary penalties to REs found to be non-compliant with the Act and associated Regulations.

Reporting terrorist and sanctioned property: Disclosures under the Special Economic Measures Act or the Justice for Victims of Corrupt Officials Act

As noted in our earlier Finance Alert, FINTRAC updates guidance on reporting terrorist and sanctioned property, reporting obligations related to terrorist and sanctioned property under the Act and associated Regulations now extend to property owned or controlled by individuals and entities under orders or regulations made under the Special Economic Measures Act (SEMA) and subsection 7(2) of the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

All REs must report to FINTRAC immediately when a disclosure duty arises under the Criminal Code, United Nations Act, SEMA, or Sergei Magnitsky Law.

Looking ahead

These amendments expand reporting, verification, and oversight expectations across multiple sectors. Where applicable, REs should review and update their compliance programs to reflect these new requirements.

FINTRAC has published new or updated existing guidance to assist REs in complying with obligations relating to these amendments as they have come into force, including:

• beneficial ownership requirements;
• money services businesses;
  • register your money services business (MSB) or your foreign money services business (FMSB)
• acquirer services in relation to private automated banking machines;
• title insurers; and
• listed persons or entity properties reported to FINTRAC.

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