Documentation · Canada

Ministerial directives under the PCMLTFA

Under Part 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the Minister of Finance can require reporting entities to apply extra measures to transactions connected with named foreign countries or entities. Three directives are in force today: Russia, Iran and North Korea (DPRK). This page sets out what each one requires, the reports and records involved, and the official lists that sit alongside them.

What a ministerial directive is

Part 1.1 gives the Minister of Finance two powers. The first is to issue a directive that requires reporting entities to apply countermeasures to transactions coming from or going to designated foreign jurisdictions or entities. The second is to recommend regulations that restrict such transactions, which is reserved for the most serious cases [2]. Part 1.1 came into force on June 19, 2014 [2].

The Minister may issue a directive only where one of four grounds applies: an international body of which Canada is a member has called on its members to act; the foreign jurisdiction's anti-money laundering or anti-terrorist financing measures are ineffective and could harm the integrity of Canada's financial system; there is a risk of facilitating the financing of threats to the security of Canada; or there is a risk of facilitating sanctions evasion [3].

A directive can require measures in five areas: verification of identity, customer due diligence (including the source of funds, the purpose of a transaction and beneficial ownership or control), monitoring of transactions or accounts, reporting to FINTRAC, and record-keeping. It can also require compliance with Part 1 and Part 1.1 of the Act [3]. Countermeasures extend obligations that already apply under the Act and its Regulations. They do not create new types of business [2].

A directive stays in force until it is revoked, suspended or amended. FINTRAC informs reporting entities when one is issued, and each directive is reviewed at least once every three years from the day it takes effect [1][2].

Who it applies to

Each current directive applies to every person or entity referred to in section 5 of the Act, which are the reporting entities [5][6][7]. The Iran directive has applied to all section 5 entities since November 15, 2025 [6].

A directive covers transactions that originate from or are bound for the named country, in any amount, including transactions below the usual reporting thresholds [5][6][7]. Whether a transaction is caught depends on the facts. Indicators include a Russian or Iranian address, Russian ruble or Iranian rial in a transfer, exchange or bank draft, and a transfer whose sending or beneficiary details point to the country. A client's identity alone, such as a foreign passport, is not enough to trigger a directive [5][6].

Directives in force

FINTRAC's list is the source for which directives are in force [1]. Check it again before each review, because directives can be amended or revoked.

What a directive requires of a business

Screening and risk assessment

Before entering a transaction that originates from or is bound for a directive country, you must have policies in your compliance program that assess the risk of a sanctions evasion offence linked to that country [6][7]. Your risk assessment must record that these transactions are high risk. Your policies must also say how you decide whether a transaction is caught and what mitigation you apply [5][6].

Client identity and due diligence

For each client who requests or benefits from a caught transaction, you must verify identity under Part 3 of the Regulations, whatever the amount. For transactions at or above the reporting threshold, you must apply enhanced measures. You must also find out the source of funds or virtual currency, the purpose of the transaction, and the beneficial ownership or control of any entity involved [5][6][7].

Monitoring and reporting

Treat each caught transaction as high risk and monitor it. Where you have reasonable grounds to suspect money laundering, terrorist financing or sanctions evasion, file a Suspicious Transaction Report (STR). If you hold property owned or controlled by a listed person or entity, file a Listed Person or Entity Property Report [5][6]. Under the Iran directive, all transactions originating from or bound for Iran must be reported to FINTRAC [6]. The guidance sets out which report type to use, which code to enter (IR2020 for Iran), and the timing. Electronic funds transfers are due within 5 working days. Large cash transactions and casino disbursements are due within 15 calendar days. Virtual currency transactions are due within 5 working days [6]. Casinos may keep using the Suspicious Transaction Report for under-threshold disbursements until December 23, 2026 [6].

Correspondent banking

Before a transaction with a foreign financial institution under a correspondent relationship, Iran and DPRK directives require you to consider the sanctions evasion risk for that country. You must also evaluate how the institution's jurisdiction applies the UN Security Council sanctions against that country [6][7].

Record-keeping

Keep records for caught transactions regardless of amount, including the source of funds and the purpose. Records must be kept for their normal retention period, or at least five years from the date they were created [5][6].

Official lists and reports involved

A directive is about jurisdictions and transactions, not a list of named people. The named-party lists come from separate sanctions regimes. FINTRAC's sanctions guidance points to the Consolidated Canadian Autonomous Sanctions List, maintained by Global Affairs Canada, and to the United Nations Security Council Consolidated List [9]. Canadian sanctions are made under the United Nations Act, the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act. Each sanctions order or regulation has its own schedule of listed persons [10]. A dealings ban applies to anyone listed, and anyone who holds their property must report it to the RCMP or CSIS [10].

FINTRAC reporting codes and sanctions evasion reports: from August 19, 2024, you must file an STR where there are reasonable grounds to suspect a transaction is related to a sanctions evasion offence. That is an offence arising from breaching an order or regulation made under the UN Act, SEMA or the JVCFOA [9][10].

Related FINTRAC bulletins, alerts and advisories

These FINTRAC products cover sanctions evasion and are often read with a directive. FINTRAC describes its special bulletins as guidance, not legal advice [12].

• Special Bulletin on financial activity associated with suspected sanctions evasion (June 2024). Covers intermediary jurisdictions, export and import controls, opaque corporate structures, non-resident banking, proxies and virtual currency [10].
• Special Bulletin on evasion of counter-proliferation sanctions (July 2025). Covers proliferation financing, trade finance, correspondent banking and intangible technology transfers. It cites the DPRK directive and the DPRK operational alert [11].
• Special Bulletin on Russia-linked money laundering activities (May 2023, reference SIRA-2023-009). Covers shell and front companies, nested correspondent banking, the SPFS payment system and virtual currency [12].
• Operational Alert on DPRK use of the international financial system (December 12, 2017, FINTRAC-2017-OA001). Covers front and shell companies and jurisdictions in northeast China and Hong Kong. The alert is older than the other items but is still in use [13].
• Joint financial intelligence advisory on illegal procurement of dual-use goods by Russian end-users (February 20, 2024, with the Dutch FIU). Covers dual-use goods, end-user checks and payment routing through third countries [14].

Penalties and enforcement

Knowingly breaching a directive's measures or its reporting requirements is an offence under subsection 74(2) of the Act. On summary conviction, the maximum fine is $2,500,000, or imprisonment for up to two years less a day, or both. On indictment, the maximum is $5,000,000, or imprisonment for up to five years, or both [4].

The administrative monetary penalty regime also applies to all directives. FINTRAC may examine whether you have met a directive during a compliance examination, and it may disclose serious non-compliance to law enforcement [1][5].

How Crown Intelligence covers this

Crown Intelligence does not hold a list of directive countries, because a directive applies to a jurisdiction and its transactions. Our data covers the sanctions and enforcement registers that work alongside directives. Each count below is live from our data service.

All registers, with publishers and counts, are on data sources filtered to Canada. Use SEMA for every SEMA register. The directive text itself is not a register, so changes to a directive will appear through FINTRAC and the Canada Gazette, not in our sanctions counts.

Practical checklist

• Confirm which directives are in force on FINTRAC's directives page, and note the date you checked [1].
• Record in your compliance program how you learn of new or amended directives and who acts on them [5][6].
• Mark Russia, Iran and DPRK as high risk in your risk assessment, and document why [5][7].
• Add a flag to transfers, exchanges, bank drafts and virtual currency transactions with a Russian, Iranian or North Korean link, including rubles and rials [5][6].
• Verify the identity of every client involved in a caught transaction, whatever the amount [5][6].
• Record source of funds or virtual currency, purpose, and beneficial ownership or control for each caught transaction [5][6][7].
• Report Iran transactions with the IR2020 code, and check the timing for each report type [6].
• File STRs where you have reasonable grounds to suspect sanctions evasion, and Listed Person or Entity Property Reports where you hold listed property [9].
• Review correspondent banking relationships against the Iran and DPRK directive measures [6][7].
• Keep records for caught transactions of any amount for at least five years [5][6].
• Keep evidence that you applied each measure, ready for a FINTRAC examination [1].

Frequently asked questions

Does a directive apply if my client is Russian?

Not by itself. A directive applies when the facts show that a transaction originates from or is bound for Russia. A Russian address or passport alone is not enough, but a transfer whose sending or beneficiary details point to Russia is caught [5].

Is a directive the same as a sanction?

No. A sanction names a person or entity and creates a dealings ban under SEMA, the UN Act or the JVCFOA [10]. A directive applies to transactions with a country or entity, whether or not a party is listed. Both can apply to the same transaction.

Do I report an Iran transaction under $10,000?

Yes, when it is caught by the Iran directive. FINTRAC requires reporting of all such transactions, using the Ministerial Directive code and the report type for that transaction. The reporting threshold does not limit this [6].

How long do directives last?

Until they are revoked, suspended or amended. Each is reviewed at least once every three years [1][2].

What happens if we do not comply?

Breaching a directive can lead to administrative monetary penalties, and knowing breaches are offences under section 74 of the Act [4]. FINTRAC may disclose serious non-compliance to law enforcement [1].

Is a sanctions evasion alert the same as a directive?

No. Sanctions evasion STRs apply to all reporting entities where there are reasonable grounds to suspect an offence, whether or not a directive covers the country [9][10].

Sources

Each source was read on 2026-10-10. Dates are as shown on each page.

1. FINTRAC, "Ministerial directives and transaction restrictions", https://fintrac-canafe.canada.ca/obligations/directives-eng. Page date modified 2025-03-21. Read 2026-10-10.
2. Department of Finance Canada, "General Information on Part 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act: Guidance", https://www.canada.ca/en/department-finance/corporate/laws-regulations/list-acts-regulations/proceeds-crime-money-laundering-terrorist-financing-act/guidance.html. Page details dated 2019-09-16. Read 2026-10-10.
3. Justice Laws Website, Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 11.42, https://laws-lois.justice.gc.ca/eng/acts/P-24.501/section-11.42.html. Current to 2026-09-21. Read 2026-10-10.
4. Justice Laws Website, Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 74, https://laws-lois.justice.gc.ca/eng/acts/P-24.501/section-74.html. Page date modified 2026-09-28. Read 2026-10-10.
5. FINTRAC, "FINTRAC guidance related to the Ministerial Directive on Financial Transactions Associated with Russia", https://fintrac-canafe.canada.ca/obligations/dir-rus-eng. Updated 2025-03-22. Read 2026-10-10.
6. FINTRAC, "FINTRAC guidance related to the Ministerial Directive on Financial Transactions Associated with the Islamic Republic of Iran", https://fintrac-canafe.canada.ca/obligations/dir-iri-eng. Updated 2026-06-23. Read 2026-10-10.
7. FINTRAC, "FINTRAC guidance related to the Ministerial Directive on the Democratic People's Republic of Korea", https://fintrac-canafe.canada.ca/obligations/dir-dprk-eng. Updated 2025-03-22. Read 2026-10-10.
8. FINTRAC, "Criminal non-compliance offences", https://fintrac-canafe.canada.ca/pen/5-eng. Page date modified 2024-09-13. Read 2026-10-10.
9. FINTRAC, "Report suspected sanctions evasion", https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/sanctions/sanctions-eng. Page date modified 2025-02-10. Read 2026-10-10.
10. FINTRAC, "Special Bulletin on financial activity associated with suspected sanctions evasion", reference FINTRAC-2024-SB002, https://fintrac-canafe.canada.ca/intel/bulletins/sanctions-eng. June 2024. Read 2026-10-10.
11. FINTRAC, "Special Bulletin on financial activity associated with evasion of counter proliferation sanctions", reference FINTRAC-2025-SB001, https://fintrac-canafe.canada.ca/intel/bulletins/proliferation-eng. July 2025. Read 2026-10-10.
12. FINTRAC, "Special Bulletin on Russia-linked money laundering activities", reference SIRA-2023-009, https://fintrac-canafe.canada.ca/intel/bulletins/rlml-eng. May 2023. Read 2026-10-10.
13. FINTRAC, "Operational alert: Democratic People's Republic of Korea's use of the international financial system for money laundering/terrorist financing", reference FINTRAC-2017-OA001, https://fintrac-canafe.canada.ca/intel/operation/oai-dprk-eng. December 12, 2017. Read 2026-10-10.
14. FINTRAC, "Joint financial intelligence advisory: illegal procurement of dual-use goods by Russian end-users", https://fintrac-canafe.canada.ca/notices-avis/avs/2024-02-20-eng. Dated 2024-02-20, modified 2024-03-22. Read 2026-10-10.

Last updated 2026-10-10