FINTRAC Penalty on Century 21 Heritage Group: A Clear Warning to Real Estate Brokers

On 10 February 2026, FINTRAC announced an Administrative Monetary Penalty (AMP) of $148,912.50 against Century 21 Heritage Group Ltd., a real estate brokerage operating in Thornhill, Alliston, Newmarket, Richmond Hill, Bradford, Hamilton, Simcoe, Milton and Kingston, Ontario. The penalty, imposed on 10 December 2025, followed a compliance examination under Part 1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its Regulations.

This case is not just about one real estate brokerage. It highlights how suspicious transaction reporting failures are now a key focus of FINTRAC enforcement and a material regulatory risk for real estate brokers and sales representatives across Canada.

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What Happened: FINTRAC's Examination Findings

Failure to Submit a Suspicious Transaction Report

FINTRAC Requirement: Under the PCMLTFA requirements, real estate brokers and sales representatives must submit a Suspicious Transaction Report (STR) to FINTRAC as soon as practicable when there are reasonable grounds to suspect that a transaction, or attempted transaction, is related to the commission or attempted commission of a money laundering or terrorist activity financing offence.

This obligation applies regardless of transaction amount and includes complex deals, unusual payment structures, third‑party involvement, and transactions that do not make economic sense. STRs are filed electronically through FINTRAC’s reporting system and, increasingly, via automated solutions and FINTRAC API integrations.

FINTRAC's finding: Century 21 Heritage Group Ltd. was found to have committed a single but serious administrative violation:

Failure to submit a suspicious transaction report where there were reasonable grounds to suspect that transactions were related to a money laundering or terrorist activity financing offence.

In other words, FINTRAC concluded that the brokerage encountered at least one transaction (or set of transactions) that met the “reasonable grounds to suspect” threshold but did not report it as required.

Why it matters: For the real estate sector, this is one of the most critical obligations. FINTRAC has repeatedly emphasized that suspicious transaction reporting is essential to its ability to generate actionable financial intelligence for law enforcement and national security agencies. When a brokerage fails to file an STR:

• Potential money laundering or terrorist activity financing linked to property transactions can go undetected.
• FINTRAC’s ability to support investigations into sanctions evasion and broader threats to the security of Canada is weakened.
• The firm shows a breakdown in its AML compliance in Canada, particularly in staff awareness, transaction monitoring, and escalation processes.

The size of the AMP—$148,912.50—for a single type of violation underscores how seriously FINTRAC views missed STRs in the real estate sector.

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Why This Penalty Matters

Real Estate Is a High-Risk Channel for Money Laundering

Real estate brokers and sales representatives are explicitly listed under the PCMLTFA alongside casinos, financial entities, money services businesses and dealers in precious metals and stones. Property transactions can involve large values, complex ownership structures, non-face-to-face clients, and cross-border flows—conditions that attract money launderers.

This case reinforces that real estate compliance is not secondary to banks and MSBs; it is central to Canada’s AML/ATF regime.

FINTRAC Is Escalating from Education to Enforcement

FINTRAC reported that in 2024–25 it issued 23 Notices of Violation, the largest number in a single year in its history, totalling more than $25 million in penalties. Since receiving AMP authority in 2008, FINTRAC has imposed more than 150 penalties across most business sectors.

The Century 21 Heritage Group AMP fits a clear pattern: where education and outreach are not enough to change behaviour, FINTRAC enforcement follows—particularly for core obligations like suspicious transaction reporting.

Suspicious Transaction Reporting Is a Strategic Priority

FINTRAC explicitly highlighted that suspicious transaction reporting is critical to its mandate. While entities must also report large cash transactions, international electronic funds transfers and large virtual currency transactions, STRs are uniquely intelligence-driven.

A failure to file STRs signals deeper weaknesses in:

• Risk assessment and red-flag identification
• Front-line training and culture
• AML audit preparedness and internal oversight

For real estate brokerages, this penalty is a reminder that STR quality and completeness are not optional—they are a top supervisory priority.

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Lessons for Reporting Entities

Strengthen Suspicious Transaction Detection and Escalation

Real estate compliance programs must define clear red flags tailored to property deals: unusual third-party payments, rapid flips, opaque beneficial ownership, or clients indifferent to price or property characteristics.

Practical steps:

• Implement checklists and workflows that prompt staff to consider whether reasonable grounds to suspect exist.
• Ensure every suspicious situation is documented, escalated, and assessed for STR filing.
• Where possible, use RegTech tools or FINTRAC API-enabled systems to streamline FINTRAC reporting and reduce manual error.

Train Front-Line Brokers and Sales Representatives Continuously

In this sector, the people who see the risk first are agents and brokers. They must understand:

• The legal test for suspicion under PCMLTFA requirements.
• How to recognize patterns that may indicate money laundering or terrorist activity financing.
• Internal procedures for confidentially escalating concerns and initiating an STR.

Annual training, case studies, and testing should be part of a documented real estate compliance program.

Align Policies, Procedures and Technology

Policies that look good on paper but are not supported by systems will not withstand a FINTRAC examination.

Actions to consider:

• Map your full client lifecycle—from onboarding and client identification to closing—to ensure STR triggers are embedded.
• Integrate deal-management platforms with compliance tools so unusual activity is flagged in real time.
• Prepare for AML audit preparedness by maintaining evidence of reviews, decisions, and all STR filings.

Conduct Independent Reviews Focused on STRs

Independent effectiveness reviews should specifically test:

• Whether past transactions that met red-flag criteria were in fact reported.
• Whether there are gaps between what staff observe and what is ultimately reported to FINTRAC.

Sampling past high-risk transactions and re-assessing them as if you were FINTRAC can reveal missed STRs before a regulator does.

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The Bigger Picture

FINTRAC’s own statistics provide important context:

• 23 Notices of Violation in 2024–25, the highest annual number ever issued by the Centre.
• More than $25 million in total AMPs in that same period.
• More than 150 penalties imposed across most business sectors since 2008.

These figures demonstrate a sustained shift from primarily guidance-driven supervision to a more assertive enforcement posture. Real estate entities are now firmly within that enforcement perimeter.

Beyond penalties, FINTRAC continues to:

• Collect and analyse data from STRs, large cash reports, international EFTs and large virtual currency transaction reporting.
• Provide financial intelligence to law enforcement and national security agencies to combat money laundering, terrorist activity financing, sanctions evasion and threats to the security of Canada.

For reporting entities, this means that investment in AML compliance in Canada is not just about avoiding an AMP; it is about contributing to a national security and public safety mandate.

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Final Thoughts

The $148,912.50 Administrative Monetary Penalty against Century 21 Heritage Group Ltd. is a clear warning to real estate brokerages that failure to submit suspicious transaction reports will attract significant regulatory consequences.

Real estate firms—whether operating from a single office or, like Century 21 Heritage Group, across multiple locations in Thornhill, Alliston, Newmarket, Richmond Hill, Bradford, Hamilton, Simcoe, Milton and Kingston—must treat STR obligations as a core business risk. Robust detection, empowered staff, aligned technology, and regular independent testing are now essential.

Those who proactively strengthen their programs today will be far better positioned for future FINTRAC examinations, evolving PCMLTFA requirements, and the next phase of Canada’s increasingly data-driven, technology-enabled AML/ATF regime.