Mortgage brokers, lenders and administrators became reporting entities on 11 October 2024. Here is what that actually requires, in the order you have to build it.
Since 11 October 2024, mortgage brokers, mortgage lenders and mortgage administrators are reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The obligations are not a lighter version of what banks do — they are the same framework, scaled to the sector.
This page summarises what applies. It is general information, not compliance advice, and FINTRAC's own guidance is the authority.
Identity verification is the visible part, but it is not the whole obligation. You also need to record the purpose and intended nature of the business relationship, monitor that relationship on an ongoing basis, determine beneficial ownership where an entity is involved, and make a politically exposed person determination.
Beneficial ownership is where mortgage files most often fall short. Where a corporation or trust is the borrower, you need to know who ultimately owns or controls it, take reasonable measures to confirm that information, and record what you did when you could not.
No dollar threshold. Filed as soon as practicable once you have reasonable grounds to suspect. Attempted transactions count.
$10,000 or more in cash, subject to the 24-hour rule that aggregates related transactions.
$10,000 or more in virtual currency, with the same 24-hour aggregation rule.
No threshold. Filed immediately where you know property is owned or controlled by a listed person or entity.
EFT reporting obligations attach to financial entities, money services businesses and casinos. A mortgage entity that separately meets the financial entity definition would be caught in that other capacity, but the mortgage sector obligations alone do not include EFTRs.
FINTRAC can issue administrative monetary penalties, classified as minor, serious or very serious, and can publish the name of a penalised entity. Amendments increasing the maximum amounts have been legislated, so check FINTRAC's current penalty page rather than relying on figures quoted anywhere else, including here.
In practice the more common exposure is not a headline penalty but an examination finding against a brokerage with a compliance program that exists on paper and nowhere else. The effectiveness review is the part most often skipped.
FINTRAC publishes sector-specific guidance for mortgage brokers, lenders and administrators at fintrac-canafe.canada.ca. Current as of 1 September 2026.
A.I.M.I. Collective brokers work with a compliance team that answers the phone. If you are carrying this on your own, that is worth a conversation.