Documentation · Canada
FINTRAC and the PCMLTFA
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) requires certain businesses to identify clients, keep records, screen for politically exposed persons, and report transactions to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This page summarises the official rules, cites each source, and shows which Canadian registers Crown Intelligence holds to support them.
What it is
The PCMLTFA is Canada's federal anti-money laundering and anti-terrorist financing law. FINTRAC is Canada's financial intelligence unit and the supervisor that checks whether businesses covered by the Act meet their obligations [1]. Businesses covered by the Act are called reporting entities. They include banks and credit unions, money services businesses, casinos, securities dealers, and other sectors listed by FINTRAC [1].
Who it applies to
Whether a business has obligations depends on its sector and activities, not its size. FINTRAC publishes a sector-by-sector guide to help businesses check [1]. A business that is unsure should check the guidance or ask FINTRAC before assuming it is out of scope.
What the Act requires of a business
| Obligation | What the official guidance says | Source |
|---|---|---|
| Compliance programme | Five elements: a designated compliance officer; written policies and procedures approved by a senior officer; a documented risk assessment; an ongoing training programme; and a two-year effectiveness review, carried out at least every two years and reported to a senior officer within 30 days. | [7] |
| Client identification | Verify the identity of clients using the methods the guidance prescribes, including the use of an agent or mandatary. The current version is effective 1 October 2025. | [6] |
| Politically exposed persons (PEPs) and heads of international organizations (HIOs) | Determine whether a client is a PEP or HIO, a family member, or a close associate. A domestic PEP holds, or has held within the last five years, a specific office at federal, provincial, territorial or municipal level. Status ends five years after the person leaves office or dies. | [8] |
| Suspicious transaction reports (STRs) | Report when there are reasonable grounds to suspect that a transaction, or an attempted transaction, is related to money laundering or terrorist financing. This is a step above simple suspicion. Submit as soon as practicable after the required measures are complete. | [2] |
| Large cash transaction reports (LCTRs) | Report receipt of $10,000 or more in cash in a single transaction, or two or more cash amounts totalling $10,000 or more within a consecutive 24-hour window. Submit within 15 calendar days. | [3] |
| Large virtual currency transaction reports (LVCTRs) | Report receipt of virtual currency equivalent to $10,000 or more in a single transaction. | [5] |
| Electronic funds transfer reports (EFTRs) | Report the transfers that the guidance specifies. The deadline is 5 business days after the transfer is initiated or finally received. | [4] |
| Listed person or entity property reports | Report immediately when you must disclose possession or control of property owned or controlled by a listed person or entity. This covers terrorist groups under the Criminal Code, persons subject to orders or regulations under the United Nations Act, and persons subject to orders or regulations under the Special Economic Measures Act (SEMA). | [9] |
| Record keeping | Keep copies of reports, including STRs, LCTRs, LVCTRs, EFTRs and listed person property reports, for at least five years. Keep the records the Regulations require for transactions and accounts. | [10] |
Penalties and enforcement
FINTRAC can issue administrative monetary penalties (AMPs) for non-compliance, and it has had this power since 30 December 2008 [12]. It must make every AMP it imposes public [12]. Penalty amounts are set within ranges in the Act and Regulations and are calculated under FINTRAC's AMP policy [11].
The Strengthening Canada's Immigration System and Borders Act (Bill C-12) received Royal Assent on 26 March 2026. It introduces a new AMP framework that allows penalties up to 40 times the previous limits, requires mandatory compliance agreements for prescribed violations, and adds compliance orders. It applies to violations that occur after 26 March 2026 [13]. Violations that occur entirely before that date continue under the former policy and amounts [13].
Criminal charges for non-compliance offences are a separate route. Both criminal charges and AMPs cannot be issued for the same instance of non-compliance [12].
The official lists involved
Screening under this regime draws on several official lists. The two main categories are the list of listed persons (sanctions and terrorist entities) and the list of politically exposed persons. FINTRAC's own penalty notices are also a public register. The table below shows the registers Crown Intelligence currently loads for Canada. Counts are read from the live API when the page loads.
| Register | Type | Records in latest load | Open |
|---|---|---|---|
| Loading live counts… | |||
Counts reflect the last successful load of each register. A count of zero or a missing row means the register did not load in the last run.
How Crown Intelligence covers this
Crown Intelligence loads the FINTRAC penalty notices and the FINTRAC money services business registry, along with the Canadian sanctions, listed-entity and PEP registers named above. Each record is credited to its publisher and dated. Live totals across all sources are on the data menu.
Data hosted in Canada.
You can search every register by name or by source. Use FINTRAC sources, SEMA sources or all Canadian sources. For a single register, open its source page from the table above.
Practical checklist
- Confirm whether your business is a reporting entity and which sector guidance applies [1].
- Appoint a designated compliance officer, and write and approve your compliance policies and procedures [7].
- Document a risk assessment that covers clients, products, channels and geographies [7].
- Set up a training programme and a two-year effectiveness review, with findings reported to a senior officer within 30 days [7].
- Verify client identity using a method from the official guidance [6].
- Screen clients for PEP and HIO status, including family members and close associates, and record your determination [8].
- Screen against the Canadian sanctions and listed-entity registers, and have a process for an immediate listed person property report [9].
- Set reporting triggers for LCTRs (15 calendar days), LVCTRs, EFTRs (5 business days) and STRs (as soon as practicable) [2] [3] [4].
- Keep copies of all reports and records for at least five years [10].
- Check the Bill C-12 changes if any violation could occur after 26 March 2026 [13].
Frequently asked questions
Is a suspicious transaction the same as a suspicion?
No. FINTRAC sets the STR threshold at reasonable grounds to suspect. That is above a hunch, but below reasonable grounds to believe, which requires verified facts [2].
How long do I keep a report?
At least five years from the date the report was sent or created, depending on the report type [10].
Who counts as a domestic PEP?
A person who holds, or has held within the last five years, a specific office at federal, provincial, territorial or municipal level. The guidance also defines family members and close associates, and sets when they stop being in scope [8].
What is the difference between an LCTR and an STR?
An LCTR is triggered by the amount of cash, not by suspicion. An STR is triggered by suspicion. You can owe both for the same transaction [3] [2].
Can FINTRAC fine me for a violation made before the new rules?
Violations that occurred entirely before 26 March 2026 continue under the former penalty policy and amounts. Violations on or after that date fall under the new framework [13].
Does Crown Intelligence provide legal advice?
No. Crown Intelligence publishes data and summaries of official sources. It does not give legal or compliance advice.
Sources
Each source was read on 2026-10-10. "Modified" is the date shown on the page.
- Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), home page. Modified 2026-06-03.
- Reporting suspicious transactions to FINTRAC: FINTRAC's compliance guidance.
- Reporting large cash transactions to FINTRAC: FINTRAC's compliance guidance.
- Reporting electronic funds transfers to FINTRAC: FINTRAC's compliance guidance.
- Reporting large virtual currency transactions to FINTRAC.
- Methods to verify the identity of persons and entities: FINTRAC's compliance guidance. Effective 1 October 2025.
- Compliance program requirements: FINTRAC's compliance guidance. Modified 2024-10-11.
- Politically exposed persons and heads of international organizations guidance: FINTRAC's compliance guidance.
- Reporting listed person or entity property to FINTRAC: FINTRAC's compliance guidance. Modified 2025-10-01.
- Record keeping requirements for financial entities: FINTRAC's compliance guidance.
- Assessment and enforcement. Modified 2025-05-30.
- Penalties for non-compliance. Modified 2023-12-15.
- Administrative monetary penalties: Changes following legislative amendments. Modified 2026-05-06.
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), Justice Laws Website. Current to 2026-09-21; modified 2026-09-28.
Last updated 2026-10-10