Anti-Money Laundering Regulation Changes: New Requirements for Reporting Entities Now in Effect

As of October 1, 2025, reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) are subject to additional requirements, as amendments to the regulations under the PCMLTFA come into effect.

Highlights

• Reporting Material Discrepancies in Beneficial Ownership Information. Reporting entities must consult Corporations Canada’s database for federally incorporated corporations which they assessed as high risk, and must file a “Beneficial Ownership Discrepancy Report” with Corporations Canada when there is material discrepancy between the reporting entity’s internal records and the beneficial ownership registry filings in the public database. Reports must be made within 30 days of the discrepancy being identified. Consult FINTRAC’s beneficial ownership requirements guidance for details on the reporting process.
  
• Using and Verifying Agents or Mandataries. Subject to certain requirements, reporting entities are authorized to use an agent or a mandatary to verify the identity of a corporation or an entity on their behalf. Money services businesses and foreign money services business must verify the eligibility of agents or mandataries that deliver money services business services on their behalf, including through criminal record checks.
  
• Listed Person or Entity Property Reporting. Reporting entities must submit a Listed Person or Entity Property Report to FINTRAC when required to make a disclosure under the Special Economic Measures Act or the Justice for Victims of Corrupt Officials Act to report the existence of property by or on behalf of a listed person or foreign national. This is in addition to existing requirements to submit such a report under the United Nations Act or the Criminal Code. Consult FINTRAC’s listed person or entity property guidance for details on the reporting process.
  
• Verifying Identity of Unrepresented Parties in Real Estate Transactions. Real estate sales representatives and brokers must verify the identity of unrepresented parties, keep records, and make the associated third-party determination for such parties in real estate transactions.
  
• New Reporting Entity Designations. Title insurers and acquirer services in relation to private automated banking machines are now subject to compliance requirements under the PCMLTFA.

For further information on the new requirements and how they might apply to your business, please contact any member of our Financial Services Regulatory Group.