Canada's anti-money-laundering stakes went up on 26 March 2026. That day, Bill C-12, the Strengthening Canada's Immigration System and Borders Act, received Royal Assent and amended the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (FINTRAC).
The numbers
| Violation type | Previous maximum | Maximum since 26 March 2026 |
|---|---|---|
| Minor | $1,000 | $40,000 |
| Serious | $100,000 | $4 million |
| Very serious | $500,000 | $20 million |
Source: McMillan.
Three changes that matter most
- A new very serious violation. Failing to maintain a compliance program that is "reasonably designed, risk-based and effective" is now itself a violation (Blakes). Having a binder of policies is no longer enough; the program has to work.
- Mandatory compliance agreements. Non-compliant entities must enter compliance agreements with FINTRAC, and breaching a compliance order is a new violation that can bring further penalties and enrollment revocation (McCarthy Tétrault).
- Universal enrollment is coming. All reporting entities, including mortgage lenders, brokers and administrators, will have to enroll with FINTRAC. FINTRAC says details will follow.
A companion statute, Bill C-15, also clarified how client identification rules apply to mortgage lenders, brokers and administrators (DLA Piper).
Why cross-border deals are higher risk
FINTRAC risk assessments expect you to weigh geography, delivery channel and client type. Non-face-to-face clients, foreign-controlled borrowers, third-party funds and cross-border wires all raise risk. A US investor funding a Canadian mortgage through a Canadian broker touches most of them.
Your six-month check-in
- Refresh your risk assessment for cross-border clients and funds
- Test the program: sample files, not just policies
- Confirm your two-year effectiveness review is current
- Prepare for FINTRAC enrollment
This content is general information for industry professionals and is not legal, tax or financial advice. Laws change and apply differently to each transaction; obtain advice from qualified counsel in each relevant jurisdiction. Legal counsel to the Cross-Border Private Lenders Association: Jasmine Daya & Co. Questions: info@cbpla.com