What are the FINTRAC obligations for mortgage brokers?

SHORT ANSWER

Five: implement a compliance program, know your client, report transactions, keep records and apply ministerial directives. They have applied to mortgage brokers, lenders and administrators since 11 October 2024.

On 11 October 2024 mortgage brokers, lenders and administrators became reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. That brought five obligations.

  • A compliance program. A named compliance officer, written policies and procedures, a risk assessment, ongoing training and a regular review of whether it all works.
  • Know your client. Verify identity and keep the information FINTRAC requires about the people and businesses you deal with.
  • Report transactions. Including suspicious transactions and large cash transactions.
  • Keep records. Retain the required records for at least five years.
  • Apply ministerial directives. Follow any directive the Minister of Finance issues.

The brokerage builds the program, but individual brokers sign the records, so every broker needs to understand them.

Our approach

A dedicated compliance team reviews files centrally, tracks licence deadlines across all three provinces and keeps the audit trail in a form a regulator can read. What does not move off your desk is the knowledge: you sign the disclosure and the FINTRAC record, so you have to understand them. This is general information rather than legal advice, and the regulator's own guidance is the authority.

Read the full guide

What each obligation requires and how a brokerage puts it in place.

FINTRAC obligations, in the order you build them

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