FINTRAC Penalty on Manor Windsor Realty: A Clear Warning to Real Estate Brokers

On 12 February 2026, FINTRAC announced an Administrative Monetary Penalty (AMP) of $107,250 against Manor Windsor Realty Ltd., a real estate brokerage based in Windsor, Ontario. The penalty, imposed on 27 November 2025, followed a compliance examination under Part 1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its Regulations.

While the amount may appear modest compared to multi-million-dollar cases, this AMP is significant for real estate compliance across Canada. It underscores that FINTRAC enforcement is no longer limited to large financial entities or money services businesses; smaller, regional brokerages are clearly in scope and expected to demonstrate mature AML compliance in Canada.

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What Happened: FINTRAC's Examination Findings

FINTRAC found that Manor Windsor Realty Ltd. committed four distinct administrative violations, all tied to the core elements of a compliance regime required under the PCMLTFA.

Failure to Maintain Written Compliance Policies and Procedures

FINTRAC requirement: Reporting entities must develop, apply, and keep up-to-date written compliance policies and procedures, approved by a senior officer. These must reflect the business’s operations and set out how it meets all PCMLTFA requirements, including client identification, record-keeping, FINTRAC reporting, and suspicious transaction reporting.

FINTRAC's finding: Manor Windsor Realty Ltd. failed to develop and apply written compliance policies and procedures that were current and formally approved by a senior officer.

Why it matters: For real estate brokerages, policies and procedures are the operational blueprint for how agents handle high-risk transactions, politically exposed persons, large cash deposits, and complex ownership structures. Without approved, written procedures, there is no clear standard for how staff should meet obligations such as large cash or large virtual currency transaction reporting, or how to escalate red flags that may lead to suspicious transaction reporting. This gap directly undermines AML audit preparedness and exposes both the firm and its agents to regulatory and reputational risk.

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Failure to Assess and Document Money Laundering and Terrorist Financing Risk

FINTRAC requirement: All reporting entities must assess and document the risk of money laundering and terrorist activity financing in the course of their activities, taking into account prescribed factors such as products, services, delivery channels, geography, and client types. This documented risk assessment must drive controls, monitoring, and resource allocation.

FINTRAC's finding: Manor Windsor Realty Ltd. failed to assess and document the risk of a money laundering offence or a terrorist activity financing offence in its business, as required, and did not adequately consider the prescribed risk factors.

Why it matters: Real estate is a well-known vehicle for layering and integrating illicit funds. In markets like Windsor, proximity to the U.S. border, cross-border buyers, and corporate ownership structures can elevate risk. Without a documented risk assessment, a brokerage cannot justify its level of monitoring, due diligence, or training. In practice, this makes it far less likely that staff will identify when FINTRAC reporting is required or escalate unusual transactions for suspicious transaction reporting.

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Failure to Develop and Maintain an Ongoing Compliance Training Program

FINTRAC requirement: Reporting entities must have a written, ongoing compliance training program tailored to their activities and staff roles. Training must cover legal obligations, internal procedures, and practical red flags relevant to the business.

FINTRAC's finding: Manor Windsor Realty Ltd. failed to develop and maintain a written, ongoing compliance training program.

Why it matters: In real estate, front-line agents and brokers are the first line of defence. They see client behaviour, payment methods, and transaction structures in real time. Without structured training, they are unlikely to recognize when a transaction triggers FINTRAC reporting, or when behaviour should prompt enhanced due diligence. This failure directly weakens the quality and volume of suspicious transaction reporting that feeds FINTRAC’s financial intelligence.

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Failure to Conduct and Document a Review of the Compliance Program

FINTRAC requirement: Reporting entities must review their compliance program at least every two years (or more often based on risk) to test its effectiveness. This review must be documented, and findings should lead to remedial actions.

FINTRAC's finding: Manor Windsor Realty Ltd. failed to institute and document the prescribed review of its compliance program for the purpose of testing its effectiveness.

Why it matters: A documented effectiveness review is the feedback loop of any compliance regime. For real estate brokerages, it is how they confirm whether policies are working, whether suspicious transaction reporting is adequate, and whether tools—potentially including FINTRAC API-based RegTech solutions—are being used effectively. Without this review, weaknesses can persist for years and only surface during a FINTRAC examination or an external investigation.

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Why This Penalty Matters

Real Estate Remains a High-Priority Sector

FINTRAC explicitly lists real estate brokers and sales representatives among the sectors required to identify clients, keep records, maintain a compliance regime, and report transactions such as large cash, large virtual currency, international electronic funds transfers, and suspicious transactions. The Manor Windsor Realty AMP reinforces that real estate is not a peripheral concern—it is central to FINTRAC enforcement strategy.

Shift from Education to Consequences

FINTRAC emphasizes collaboration and guidance, but this case shows that when basic compliance regime elements are missing, Administrative Monetary Penalties will follow. Even a single-location or regional brokerage can face a six-figure AMP if it neglects foundational PCMLTFA requirements. This is a clear signal that “we’re small” is not a defence.

Expectations Are Rising Across All Business Sizes

The violations here are not about complex analytics or advanced RegTech; they concern baseline obligations: policies, risk assessment, training, and effectiveness review. If a brokerage is missing any of these, it is now clearly at risk of enforcement. Real estate firms should assume that future examinations will look for more sophisticated practices, including better data, technology use, and demonstrable AML audit preparedness.

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Lessons for Reporting Entities

Build and Approve Tailored Policies and Procedures

Real estate brokerages should:

• Draft written policies that reflect their actual business model, locations, and client base.
• Ensure approval by a senior officer and document that approval.
• Embed clear procedures for client identification, record-keeping, FINTRAC reporting, and escalation of red flags.

Conduct a Formal, Documented Risk Assessment

Firms must:

• Identify and document their inherent risks: types of properties, non-resident buyers, cash purchases, third-party payments, and corporate ownership.
• Consider geography, including cross-border factors and local market dynamics.
• Use the risk assessment to determine when enhanced due diligence and closer monitoring are necessary.

Implement an Ongoing Training Program, Not One-Off Sessions

Effective real estate compliance requires:

• A written training curriculum tailored to agents, brokers, and administrative staff.
• Regular refreshers (e.g., annually) with attendance tracked.
• Practical case studies on suspicious transaction reporting and red flags specific to real estate, such as rapid resales or opaque beneficial ownership.

Test Compliance Effectiveness and Document the Results

Brokerages should:

• Perform a structured review of the compliance program at least every two years.
• Test whether policies are followed, training is absorbed, and reports are filed accurately and on time.
• Document findings, action plans, and follow-up. This documentation is critical for AML audit preparedness and future FINTRAC examinations.

Leverage Technology and FINTRAC API-Enabled Tools

While the Manor Windsor case focused on regime basics, the direction of travel is clear: better use of data and automation. Consider:

• Using RegTech tools to centralize client data and flag high-risk patterns.
• Integrating solutions that can interact with FINTRAC API services where available, to streamline FINTRAC reporting and reduce manual error.
• Automating tracking of training, policy updates, and review cycles.

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The Bigger Picture

FINTRAC’s news release situates this AMP within a broader enforcement trend. In 2024–25, FINTRAC issued 23 Notices of Violation, the largest number in a single year in the Centre’s history, totalling more than $25 million in penalties. Since gaining authority to impose AMPs in 2008, FINTRAC has imposed more than 150 penalties across most business sectors.

This trajectory confirms a sustained shift from primarily education-focused supervision toward consistent, visible FINTRAC enforcement. FINTRAC continues to highlight the importance of suspicious transaction reporting as a critical input to financial intelligence that supports law enforcement and national security agencies in combating money laundering, terrorist activity financing, sanctions evasion, and threats to Canada’s security.

Real estate brokerages, alongside casinos, financial entities, money services businesses, and others, are expected to contribute meaningfully to this intelligence through robust compliance regimes and accurate, timely reporting.

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Final Thoughts

The $107,250 AMP against Manor Windsor Realty Ltd. is a pointed reminder that FINTRAC expects even mid-sized and regional real estate brokerages to have fully functioning compliance regimes: written and approved policies, documented risk assessments, ongoing training, and regular effectiveness reviews.

For real estate firms, the takeaway is clear: invest now in foundational AML compliance in Canada, supported by appropriate technology and governance, or risk becoming the next public example in FINTRAC’s growing list of enforcement actions. Aligning people, processes, and tools today is the most effective way to avoid future AMPs and to meet the spirit and letter of the PCMLTFA requirements.