EstatePass
Compliance Tool

FINTRAC Compliance Checklist

Stay compliant with Canada's anti-money laundering requirements. This interactive checklist covers all FINTRAC obligations for real estate professionals, including client identification, record keeping, suspicious transaction reporting, and beneficial ownership.

0 of 13 items completed
Client Identification
Verify the identity of every client before or during the transaction.
0/3

Confirm the identity of every individual client using acceptable methods.

Use government-issued photo ID (passport, driver's licence, permanent resident card)
ID must be valid (not expired) at time of verification
Record: name, date of birth, ID type, ID number, issuing jurisdiction
Verify before or within 30 days of the transaction
Ref: PCMLTFA s.6.1; PCMLTFR s.105

Confirm the existence and identity of any corporation, partnership, or trust involved.

Obtain articles of incorporation, certificate of corporate status, or partnership agreement
Record: legal name, address, nature of business, incorporation number
For trusts: obtain trust deed and identify all trustees
Confirm the entity is not a shell company being used for money laundering
Ref: PCMLTFR s.109, 110, 111

Identify not just your client but all parties involved in the purchase/sale.

Both buyer and seller must be identified
If acting for one party, still record available information on the other
Identify signatories on behalf of corporations
Identify all individuals with signing authority
Ref: PCMLTFR s.105-111
Record Keeping
Maintain required records for a minimum of 5 years after the transaction.
0/3

Keep all identity verification documents and records on file.

Keep copies of all identification documents used
Record the method used to verify identity
Store the date of verification
Retain records for at least 5 years after the last transaction
Ref: PCMLTFR s.144

Keep detailed records of every real estate transaction.

Record: property address, purchase price, names of all parties
Record: date of transaction and date of closing
Keep copies of the Agreement of Purchase and Sale
Record details of all funds received and disbursed
Ref: PCMLTFR s.143

Document the receipt of any funds, including deposits.

Record: date received, amount, currency, source of funds
Record: name of person from whom funds were received
Record: whether funds were received in cash, cheque, wire, or other method
Keep for 5 years from the date of receipt
Ref: PCMLTFR s.130
Suspicious Transaction Reporting
Report transactions where there are reasonable grounds to suspect money laundering or terrorist financing.
0/2

Be aware of red flags that may indicate money laundering in real estate.

Client is reluctant to provide identification or provides questionable documents
Transaction involves unusual or complex arrangements with no apparent purpose
Property purchased at significantly above or below market value
Client insists on paying large amounts in cash
Client uses multiple accounts or third parties without clear reason
Source of funds is unclear or inconsistent with client's profile
Ref: PCMLTFA s.7; FINTRAC Guidance

Submit STRs to FINTRAC within 30 days of detecting suspicious activity.

File within 30 calendar days of detecting the suspicious activity
Report if there are reasonable grounds to suspect ML or TF
You do NOT need to prove the activity is criminal — suspicion is sufficient
Do NOT inform the client that an STR has been filed (tipping off is an offence)
Filing an STR does not mean the transaction must be stopped
Ref: PCMLTFA s.7(1)
Large Cash Transaction Reporting
Report any cash transaction of $10,000 or more.
0/2

Monitor for single or combined cash transactions totalling $10,000+ within 24 hours.

Applies to cash (banknotes and coins) only — not cheques, wire transfers, or drafts
Includes multiple cash transactions totalling $10,000+ within a 24-hour period
You do not need to suspect anything — reporting is automatic at the threshold
Record: amount, currency, client name, date, transaction details
Ref: PCMLTFA s.7(a); PCMLTFR s.131

Submit LCTRs to FINTRAC within 15 calendar days.

File within 15 calendar days of the transaction
Report to FINTRAC electronically through their reporting system
Include all required fields: client ID, amount, date, account details
Keep a copy of the report in your records for 5 years
Ref: PCMLTFR s.132
Third Party Determination
Determine whether a third party is directing the transaction.
0/1

Determine if the transaction is being conducted on behalf of a third party.

Ask every client: "Is this transaction being conducted on behalf of another person or entity?"
If yes: record the name, address, date of birth, and relationship of the third party
If the client is a corporation: determine who the directing individuals are
Document the response regardless of whether a third party is identified
Ref: PCMLTFR s.134
Beneficial Ownership
Identify the beneficial owners of corporate clients and trusts.
0/2

Identify individuals who ultimately own or control 25%+ of the entity.

For corporations: identify all individuals who own or control 25% or more of shares
For trusts: identify all trustees, beneficiaries, and settlers/grantors
Record: name, address, date of birth, and nature of interest for each beneficial owner
Verify the information obtained using reliable sources
Update beneficial ownership information when changes are detected
Ref: PCMLTFR s.138

Verify beneficial ownership information using reliable sources and documentation.

Review corporate registry filings and shareholder agreements
Cross-reference with publicly available information
Ask the client to confirm beneficial ownership in writing
Document all steps taken to verify beneficial ownership
Ref: PCMLTFR s.138(2)

FINTRAC Non-Compliance Penalties

Administrative Penalties

Up to $100,000 per violation for individuals and $500,000 per violation for entities. Penalties are published on FINTRAC's website.

Criminal Penalties

Up to $2,000,000 in fines and up to 5 years imprisonment for serious non-compliance or failure to report.

Regulatory Action

Provincial regulators (RECO, BCFSA, RECA) can suspend or revoke licences for failure to comply with FINTRAC requirements.

Frequently Asked Questions

FINTRAC Compliance for Canadian Real Estate Professionals

Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) imposes significant obligations on real estate professionals. As a real estate agent, broker, or brokerage in Canada, you are considered a “reporting entity” under the Act and must comply with a comprehensive set of anti-money laundering (AML) and anti-terrorist financing (ATF) requirements. Failure to comply can result in severe administrative penalties, criminal prosecution, and loss of your real estate licence. This interactive checklist helps you track and complete every requirement.

Why Real Estate Is a Target for Money Laundering

Real estate transactions are attractive to money launderers because they involve large sums of money, can increase in value over time, and can be structured in complex ways using corporations, trusts, and nominees. The Canadian real estate market, particularly in major cities like Toronto and Vancouver, has been identified as vulnerable to money laundering. The federal government has responded by strengthening FINTRAC requirements and increasing enforcement. Provincial regulators have also increased their focus on AML compliance as a condition of maintaining a real estate licence.

The Six Pillars of FINTRAC Compliance

FINTRAC compliance for real estate professionals is built on six key pillars. First, client identification requires verifying the identity of every person and entity involved in a transaction. Second, record keeping mandates maintaining detailed records for at least five years. Third, suspicious transaction reporting requires filing reports when you suspect money laundering or terrorist financing. Fourth, large cash transaction reporting requires automatic reporting of cash transactions of $10,000 or more. Fifth, third party determination requires asking whether anyone else is directing the transaction. Sixth, beneficial ownership requires identifying the true owners behind corporate entities and trusts.

Compliance Is an Exam Topic and a Career Requirement

FINTRAC compliance is tested on Canadian real estate licensing exams in all provinces. RECO, BCFSA, and RECA all include questions on anti-money laundering obligations, client identification procedures, and reporting requirements. Beyond the exam, compliance is an ongoing professional requirement throughout your career. Provincial regulators conduct audits and investigations, and non-compliance can result in disciplinary action, fines, and licence suspension or revocation. Understanding these requirements is not optional — it is essential for every Canadian real estate professional.

Staying Up to Date

FINTRAC requirements evolve as the government responds to new money laundering threats and techniques. Real estate professionals should regularly review FINTRAC guidance documents, attend compliance training offered by their brokerage and provincial regulator, and ensure their record-keeping systems meet current standards. The checklist on this page reflects current requirements but should be used alongside official FINTRAC guidance and your brokerage's compliance program.

Related Canadian Real Estate Resources

Regulatory Practice Questions

Practice FINTRAC and compliance questions

Exam Readiness Quiz

10-question diagnostic across all topics

Licensing Comparison

Compare requirements across provinces

Practice Regulatory Exam Questions

Master FINTRAC, trust accounts, and compliance topics for your Canadian real estate exam.

Start Regulatory Practice