Last reviewed: 8 October 2026
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FINTRAC’s anti-money-laundering obligations for Canadian mortgage brokers, explained
Our FCAC explainer covers a federal regulator whose authority stops at federally regulated banks. FINTRAC is a different federal layer: one that reaches provincially licensed mortgage brokers directly, whichever province licensed them.
Who is covered
FINTRAC’s sector guidance, updated effective October 11, 2024, defines a mortgage broker as a person or entity authorized under provincial legislation to act as an intermediary between a lender and a borrower on loans secured by mortgages on real property or hypothecs on immovables.[1] A mortgage administrator is a person or entity, other than a financial entity, in the business of servicing mortgage agreements for lenders, and a mortgage lender is a person or entity, other than a financial entity, in the business of providing such loans.[1] The legal references are section 5(i) of the PCMLTFA and sections 1(2) and 64.1 of its Regulations.[1] If you are an employee, FINTRAC says the requirements are your employer’s responsibility, except reporting suspicious transactions, which applies to both employee and employer.[1]
The obligations at a glance
| Obligation | What FINTRAC’s guidance says |
|---|---|
| Compliance program | Appoint a compliance officer; keep written, up-to-date policies and procedures (approved by a senior officer if the business is an entity); document a risk assessment; run a written training program with a plan; and review the program’s effectiveness at least every two years.[2] |
| Identity verification | Required for suspicious transactions, large cash transactions ($10,000 or more in cash), large virtual currency transactions, and when a receipt of funds record, information record or mortgage loan record is kept. For receipt of funds, a person is identified when funds are received and a corporation or other entity within 30 days.[3] |
| Beneficial ownership | For entities, obtain and take reasonable measures to confirm beneficial ownership: the individuals who directly or indirectly own or control at least 25% of a corporation or non-corporate entity.[4] |
| Politically exposed persons | Take reasonable measures to determine whether a person is a politically exposed person, head of an international organization, or a family member or close associate, including when receiving $100,000 or more in cash or virtual currency.[5] |
| Reports to FINTRAC | Suspicious Transaction Reports, Listed Person or Entity Property Reports, Large Cash Transaction Reports and Large Virtual Currency Transaction Reports, with a 24-hour rule for the large-transaction reports; FINTRAC’s sector page also has a separate report for suspected sanctions evasion (added June 25, 2024).[1] |
| Record keeping | Records must be kept so they can be provided to FINTRAC within 30 days of a request; the retention periods listed for the main records are at least five years.[6] |
Client identification and beneficial ownership
FINTRAC describes client identification information as the identifying information you have on clients, such as name, address, telephone number, occupation or nature of principal business, and date of birth for an individual.[1] Beneficial owners must be individuals; another corporation or entity cannot be the beneficial owner.[4] Since October 1, 2025, a reporting entity must also consult Corporations Canada’s database to check whether any corporations it has assessed as high risk for money laundering or terrorist financing, and that are incorporated under the Canada Business Corporations Act, show a material discrepancy against the individuals with significant control listed there. If there is one, it must report the discrepancy to Corporations Canada within 30 days and keep the acknowledgement; a discrepancy resolved within 30 days does not have to be reported.[4]
Politically exposed persons and enhanced measures
For a foreign politically exposed person, or a family member or close associate of one, the guidance requires reasonable measures to establish the person’s source of wealth plus enhanced measures such as additional identity verification and enhanced ongoing monitoring. For a domestic politically exposed person, head of an international organization or their family members, those steps apply where the entity’s risk assessment finds a high risk of a money laundering or terrorist financing offence. The source-of-wealth step has a 30-day window after the business relationship begins or the fact is detected.[5] More generally, if a reporting entity considers the risk of money laundering, terrorist financing or sanctions evasion to be high, it must take enhanced measures and have written policies for them.[2]
Suspicious transaction reports
The reporting threshold is “reasonable grounds to suspect” that a completed or attempted transaction is related to a money laundering or terrorist activity financing offence, a step above simple suspicion (a hunch with no supporting facts): there is a possibility, supported by facts or indicators, that an offence has occurred.[7] There is no fixed dollar threshold in that test. The report must be submitted “as soon as practicable” after completing the measures that let the entity establish reasonable grounds to suspect, and FINTRAC says the report must be treated as a priority.[7] An entity is not allowed to inform anyone, including the client, of a report’s contents or that one has been or will be made, if the intent is to prejudice a criminal investigation, and an entity that believes verifying identity would tip the client off does not have to take that step.[7, 3]
How this compares with the US rule
The US equivalent for non-bank mortgage lenders and originators uses a $5,000 floor and a 30-day filing clock; see AML programs and Suspicious Activity Reports. The two systems are separate, and a US rule does not tell you what the Canadian one requires.
What this doesn’t replace
None of this substitutes for the province’s own licensing and conduct rules covered elsewhere in this Library. Confirming the broker’s actual provincial license still matters; see our license-checking explainer, and for the provincial conduct layer, the MBRCC’s national Code of Conduct.
Correction (8 October 2026): the earlier version of this page (a) described the October 1, 2025 beneficial-ownership change as a general “discrepancy-reporting expectation”; FINTRAC’s guidance makes it a duty tied to entities assessed as high risk that are incorporated under the Canada Business Corporations Act, and the text above now says so; (b) said guidance on politically exposed persons was updated in November 2025, a date that FINTRAC’s guidance does not state, and it has been removed; and (c) described enhanced due diligence as covering the “source of funds” and “higher-risk jurisdictions”; the guidance cited above refers to source of wealth for politically exposed persons, and the jurisdiction reference has been removed. See the updates log.