The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has updated its guidance for Ultimate Beneficial Ownership guidance for Canadian businesses under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
Through this guidance, FINTRAC intends to provide explanations on the Beneficial Ownership requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations. According to the agency, as of 1 October 2025, all entities must consult Corporations Canada’s database for corporations integrated under the Canada Business Corporations Act that they have assessed as posing a substantial risk of money laundering or terrorist activity financing.
FINTRAC’s updated guidance
These updates apply to a wide range of reporting entities across Canada, including money services businesses (MSBs), foreign money services businesses (FMSBs), financial institutions, and other businesses subject to FINTRAC supervision. Additionally, the changes centre on three areas, including agent verification for MSBs, beneficial ownership requirements, and listed person or entity property reporting.
This comes as a significant shift in Canada’s AML/ATF regime, with compliance expectations increasing for all entities operating across the region.
Requirements for MSBs and FMSBs
For MSBs and FMSBs, FINTRAC now requires them to verify the eligibility of their agents or mandataries who provide services on their behalf, including conducting criminal records checks to ensure that agents meet all compliance standards. To summarise, as of the announcement, all these entities must review their agent relationships and implement criminal record screening as part of their compliance programmes.
Obligations for Beneficial Ownership
With these updates, Canada aims to fall in line with international standards that mandate Beneficial Ownership transparency, becoming a global AML urgency. Now, businesses are required to consult Corporations Canada’s Beneficial Ownership database for corporations incorporated under the Canada Business Corporations Act (CBCA) that they have evaluated as high risk. Additionally, FINTRAC underlines that businesses must file a Beneficial Ownership Discrepancy Report with Corporations Canada if a material discrepancy between the data the business collects during the KYC process and the Individual with Significant Control (ISC) information in the Corporations Canada database exists.
Listed Person or Entity Property Report
FINTRAC highlighted that sanctions compliance is more closely linked to AML requirements. With this update, the agency now demands that all businesses subject to the PCMLTFA submit a Listed Person or Entity Property Report to FINTRAC when they disclose property under the Special Economic Measures Act (SEMA) and Justice for Victims of Corrupt Foreign Officials Act (JVCFOA). This new requirement follows an earlier change from March 2025, which demanded reporting under the United Nations Act and Criminal Code.
