FINTRAC Compliance for Accountants & Accounting Firms

When Do Accountants Have FINTRAC Obligations?

Not every accounting activity triggers FINTRAC obligations. You become a reporting entity under the PCMLTFA only when you carry out specific activities on behalf of a client. Understanding exactly when your obligations are activated is the first step to compliance.

Your FINTRAC obligations apply when you:

• Receive or pay funds on behalf of a client (other than fees for your own professional services)
• Purchase or sell securities, real property, or business assets on behalf of a client
• Transfer funds or securities by any means on behalf of a client
• Give instructions on behalf of a client for any of the above activities
• Act as a signatory on a client's account
• Create, organize, or arrange the incorporation of a company, limited partnership, trust, or other entity on behalf of a client

If your practice is limited to tax preparation, auditing, bookkeeping, or advisory work that does not involve these activities, you are not a reporting entity for those engagements.

What You Must Do When Obligations Apply

When you carry out a triggering activity, your obligations mirror those of other reporting entities:

• Client identification: Verify the identity of every client for whom you carry out a triggering activity, using reliable and independent source documents.
• Record-keeping: Maintain records of the triggering activity, client identification, and any funds received or disbursed. Records must be kept for at least five years.
• Large Cash Transaction Reports (LCTR): File an LCTR if you receive $10,000 or more in cash in connection with a triggering activity.
• Suspicious Transaction Reports (STR): File an STR if you have reasonable grounds to suspect that a transaction related to a triggering activity involves money laundering or terrorist financing.
• Compliance program: Maintain a written compliance program including policies, procedures, a risk assessment, a compliance officer, and an ongoing training plan.

Why This Creates Challenges for Accounting Firms

• Inconsistent trigger points: Some client engagements trigger FINTRAC obligations and others do not. An accountant preparing tax returns for 200 clients may have FINTRAC obligations for only a handful of them. Tracking which engagements are in scope requires clear internal processes.
• Client identification across long relationships: Accountants often have longstanding client relationships where identification was never formally documented to FINTRAC standards. Retroactively verifying identity for existing clients who engage you for a triggering activity adds friction.
• Recognizing suspicious activity: Accountants see detailed financial information, but they are trained to focus on accuracy, not AML risk. Identifying when a client's instructions or transaction patterns raise money laundering concerns requires a different lens.
• Small firm resource constraints: Many accounting practices are small firms or sole practitioners. Building and maintaining a full compliance program with policies, risk assessments, and ongoing training is a significant administrative burden.

How Comply+ Helps Accountants Stay Compliant

Triggering Activity Tracking

Comply+ helps you classify engagements based on whether they involve triggering activities. When an engagement is in scope, the platform guides you through your reporting and record-keeping obligations for that specific client.

Automated LCTR Filing

When you receive cash above the reporting threshold in connection with a triggering activity, Comply+ generates a pre-filled LCTR with client information and submits it directly to FINTRAC.

STR Detection and Narrative Support

Our aiSTR technology flags transaction patterns that align with FINTRAC risk indicators relevant to accounting. Draft narratives are generated automatically, reducing the time between identification and filing.

Compliance Program Support

Comply+ maintains a complete audit trail of all reports filed, decisions made, and client identification records. When FINTRAC conducts an examination, your documentation is organized and accessible.

Record Keeping Requirements

FINTRAC publishes official guidance on record keeping for accountants. For full details and current requirements, see: Record keeping requirements for accountants (FINTRAC).