FINTRAC Regulatory Changes in Effect October 1, 2025: What Canadian Businesses Need to Know
On October 1, 2025, new FINTRAC regulatory requirements officially came into force under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). These changes impact a wide range of reporting entities in Canada—including money services businesses (MSBs), foreign money services businesses (FMSBs), financial institutions, and other businesses subject to FINTRAC supervision.
The updates focus on three major areas: agent verification for MSBs, beneficial ownership requirements, and listed person or entity property reporting. Below we break down each requirement and explain how businesses can stay compliant.
1. New Obligations for Money Services Businesses and Foreign MSBs
One of the most significant updates affects money services businesses (MSBs) and foreign money services businesses (FMSBs) operating in Canada.
What's new?
- MSBs and FMSBs must now verify the eligibility of their agents or mandataries who deliver services on their behalf.
- This includes conducting criminal record checks to ensure agents meet compliance standards.
Why it matters: MSBs often operate through large agent networks, especially in remittances and virtual currency services. These networks have historically been exploited for money laundering and terrorist financing. By requiring agent due diligence, FINTRAC aims to close a critical vulnerability in Canada's AML regime.
Key takeaway: MSBs and FMSBs must immediately review their agent relationships and implement criminal record screening processes as part of their compliance program.
2. Beneficial Ownership Requirements and Discrepancy Reporting
Beneficial ownership transparency has become a global AML priority, and Canada is aligning with international standards.
What's new?
- Businesses must consult Corporations Canada's beneficial ownership database for corporations incorporated under the Canada Business Corporations Act (CBCA) that they have assessed as high risk.
- If there is a material discrepancy between the information a business collects (during KYC) and the Individuals with Significant Control (ISC) information in the Corporations Canada database, the business must file a Beneficial Ownership Discrepancy Report with Corporations Canada.
Why it matters: Shell companies and opaque corporate structures are frequently used to launder money. By requiring reporting entities to cross-check beneficial ownership against official records and report discrepancies, FINTRAC and Corporations Canada gain stronger tools to combat illicit finance.
Key takeaway: High-risk corporate clients now come with additional verification and reporting obligations. Businesses must update their KYC workflows and AML policies to incorporate this database consultation and reporting process.
3. Listed Person or Entity Property Report
Sanctions compliance is becoming increasingly intertwined with AML obligations.
What's new?
Businesses subject to the PCMLTFA must submit a Listed Person or Entity Property Report to FINTRAC when they disclose property under the:
- Special Economic Measures Act (SEMA)
- Justice for Victims of Corrupt Foreign Officials Act (JVCFOA)
This requirement builds on an earlier change (effective March 2, 2025), which already required reporting under the United Nations Act and Criminal Code.
Why it matters: Sanctions lists are expanding globally, and Canada is strengthening its oversight. Businesses must ensure they can identify, freeze, and report property connected to listed persons or entities—whether under sanctions, corruption laws, or terrorism financing laws.
Key takeaway: If your business identifies assets belonging to or controlled by a listed person or entity, you must file a property report with FINTRAC in addition to other required disclosures.
How Technology and the FINTRAC API Can Help
The October 1, 2025 regulatory changes add more complexity to AML compliance. Manual processes increase the risk of missed obligations, especially around beneficial ownership checks, agent due diligence, and sanctions reporting.
The FINTRAC API and RegTech solutions like Comply+ can help businesses:
- Automate LCTR, LVCTR, EFTR, and STR reporting to FINTRAC.
- Maintain audit-ready records of agent due diligence, including criminal record checks.
- Cross-reference corporate clients against Corporations Canada's beneficial ownership database.
- Streamline Beneficial Ownership Discrepancy Reports submission.
- Monitor and automate Listed Person or Entity Property Reports for sanctions compliance.
By integrating compliance automation into daily operations, businesses can reduce risk, increase accuracy, and avoid costly enforcement actions.
Impact on Different Business Types
Money Services Businesses (MSBs)
- • Agent verification and criminal record checks
- • Enhanced due diligence documentation
- • Updated compliance policies for agent networks
Financial Institutions
- • Beneficial ownership database checks
- • Discrepancy reporting procedures
- • Enhanced sanctions screening
Securities Dealers
- • Listed person property reporting
- • Enhanced KYC for high-risk corporates
- • Sanctions compliance updates
Other Reporting Entities
- • Property disclosure obligations
- • Updated reporting workflows
- • Enhanced compliance monitoring
How Comply+ Helps with New Regulatory Requirements
At Comply+, we help businesses navigate the new October 2025 FINTRAC requirements with:
- Automated FINTRAC reporting through direct API integrations for all report types.
- Agent due diligence tracking and criminal record check documentation.
- Beneficial ownership database integration and discrepancy reporting workflows.
- Listed person and entity property monitoring and automated reporting.
- Compliance program updates to meet new regulatory standards.
- Training modules covering the October 2025 regulatory changes.
Final Thoughts
The October 1, 2025 FINTRAC regulations represent a major shift in Canada's AML/ATF regime. With expanded obligations for MSBs, enhanced beneficial ownership transparency, and stricter sanctions reporting, businesses must adapt quickly.
The message is clear: compliance expectations are rising. Businesses that invest in FINTRAC reporting automation and RegTech solutions will be better positioned to meet these new requirements and avoid penalties.
Now is the time to review your compliance program, update your policies, and ensure your systems are ready for this new era of AML regulation.
Navigate the New FINTRAC Requirements with Confidence
Don't let regulatory changes overwhelm your compliance program. Comply+ offers automated solutions to help you meet the new October 2025 FINTRAC requirements efficiently and accurately.