FINTRAC Compliance for Mortgage Professionals

Automated FINTRAC reporting for mortgage administrators, brokers, and lenders. Comply+ handles your reporting obligations so you can focus on helping clients secure financing.

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FINTRAC Obligations for Mortgage Professionals

Mortgage administrators, brokers, and lenders are reporting entities under the PCMLTFA. If you administer, arrange, or provide mortgage financing, you have obligations to verify client identity, monitor for suspicious activity, file reports with FINTRAC, and maintain a written compliance program.

Mortgage transactions involve large sums of money flowing between multiple parties: buyers, sellers, lenders, lawyers, and intermediaries. This complexity makes the mortgage process a known vulnerability for money laundering, and FINTRAC expects mortgage professionals to play an active role in detecting and reporting it.

What You Must Report

Large Cash Transaction Reports (LCTR)

If you receive $10,000 or more in cash in connection with a mortgage transaction (for example, a cash down payment), file an LCTR within 15 calendar days. While most mortgage payments are made electronically, cash components of transactions must still be monitored.

Electronic Funds Transfer Reports (EFTR)

International wire transfers of $10,000 or more related to mortgage financing require an EFTR within 5 working days. This applies when funds for a down payment or mortgage repayment originate from outside Canada.

Suspicious Transaction Reports (STR)

File an STR when you have reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing. Suspicious patterns in the mortgage context include:

  • Down payments funded by cash from unverified sources
  • Clients who use nominees or shell companies to purchase properties without a clear business reason
  • Mortgage applications where the stated income does not support the loan amount
  • Requests to rush closing without standard due diligence
  • Funds arriving from multiple unrelated third parties

Deadline: As soon as practicable.

Compliance Challenges in the Mortgage Industry

  • Source of funds verification: Down payments can come from savings, gifts, other property sales, or foreign sources. Tracing and verifying the legitimate origin of funds is time-consuming but essential. FINTRAC expects you to document where the money came from, not just that it arrived.
  • Multiple parties in a single transaction: A typical mortgage transaction involves the buyer, the seller, real estate agents, lawyers, the lender, and sometimes a mortgage broker. Each party may have their own FINTRAC obligations, and understanding where yours begin and end requires clarity.
  • Private lending and alternative mortgages: Private lenders and alternative mortgage providers operate outside the traditional banking system. Their clients often come with higher-risk profiles. Compliance programs for private lending must account for the elevated AML risk inherent in this segment.
  • Broker networks: Mortgage brokers work with multiple lenders and process applications from a wide range of clients. Ensuring that every application is subject to proper identification, verification, and risk assessment requires disciplined processes across the network.
  • Record-keeping over time: Mortgages are long-lived financial products. Records related to the origination, including client identification and source-of-funds documentation, must be retained for at least five years after the mortgage relationship ends.

How Comply+ Supports Mortgage Compliance

Automated Report Detection

Upload your transaction and client data. Comply+ identifies reportable cash receipts and international wire transfers, generates pre-filled LCTRs and EFTRs, and submits directly to FINTRAC.

STR Detection for Mortgage Transactions

Our aiSTR technology flags mortgage-related transactions that match FINTRAC risk indicators: unusual funding sources, third-party payments, income inconsistencies, and rush-closing patterns. Each flag comes with a draft narrative for your team to review.

Client Identification and Record Management

Comply+ stores client identification records alongside transaction data, creating a complete compliance file for each mortgage engagement. Retrieval during a FINTRAC examination is straightforward.

Direct FINTRAC Submission

Submit all report types directly to FINTRAC from the platform. Confirmation receipts and a full audit trail are maintained automatically.

Mortgage transactions are large, complex, and involve multiple parties. Comply+ cuts through that complexity by automating the detection and reporting that FINTRAC requires from mortgage professionals.

Record Keeping Requirements

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

Enforcement & Penalties

The Cost of Non-Compliance

FINTRAC enforcement is intensifying. Recent penalties demonstrate that compliance failures result in significant financial consequences, with Bill C-2 increasing maximum penalties to $20 million for entities.

Recent FINTRAC Penalties

FINTRAC has imposed significant Administrative Monetary Penalties (AMPs) for compliance failures across multiple sectors.

Juba Express Inc. — $67,150

December 2025 — Toronto, Ontario

Multiple compliance failures including no effective compliance regime, no proper risk assessment, and failures to submit EFT and LCT reports.

Read case study

MP Technology Services Ltd. — $536,853.35

December 2025 — Foreign MSB (Seychelles)

Failed to submit STRs for transactions with exposure to darknet marketplaces, sanctioned entities, and child sexual abuse material.

Read case study

Xeltox Enterprises (Cryptomus) — $176,960,190

October 2025 — British Columbia

2,593 violations including 1,068 unreported STRs, 1,518 unreported LVCTRs, and failure to comply with Ministerial Directive on Iran.

Read case study

KuCoin (Peken Global) — $19,552,000

September 2025 — Foreign MSB (Seychelles)

Unregistered foreign MSB, 2,952 unreported LVCTRs, and 33 unreported STRs linked to darknet marketplaces and illicit chemical trade.

Read case study

Bill C-2: Increased Penalties

Under Bill C-2 (tabled June 2025), maximum Administrative Monetary Penalties would increase dramatically:

  • Entities: Up to $20 million (previously $500,000) — a 40x increase
  • Individuals: Up to $4 million (previously $100,000)
  • Criminal penalties: Certain compliance failures can result in criminal prosecution
Learn more about Bill C-2

Enforcement Trends

  • 23 Notices of Violation issued in 2024–25, the highest annual volume since 2008
  • More than $25 million in total penalties in 2024–25
  • Over 150 penalties imposed since 2008 across all regulated sectors
  • FINTRAC is moving to a supervisory model anchored in credible deterrence

Why Choose Comply+

Purpose-built for Canadian FINTRAC compliance. Automate reporting, reduce risk, and scale your operations.

Comprehensive Reporting

Handle all FINTRAC transaction types with automated LCTR, LVCTR, EFTR, and STR detection and submission. Our system identifies reportable transactions across cash, virtual currency, and electronic funds transfers.

AI-Powered Detection

Our proprietary aiSTR™ technology automatically flags suspicious transactions and drafts FINTRAC-compliant narratives. Reduce false positives and ensure nothing falls through the cracks.

Scalable Operations

Scale your operations without increasing compliance overhead. Automate reporting workflows to handle growth from hundreds to thousands of transactions per month.

Platform Features

Complete FINTRAC Compliance Solution

From batch uploads to direct FINTRAC submission — everything you need in one platform

Direct FINTRAC Submission

Submit reports directly to FINTRAC securely. No need to log in to the FINTRAC website — everything is handled within Comply+.

Autopilot Mode for Connected Databases

For fully connected databases, enable autopilot for automatic submission of LCTRs, LVCTRs, and EFTRs. Our proprietary aiSTR™ technology handles suspicious transaction detection, requiring manual review only for STRs.

Intelligent Batch Processing

For non-connected databases, upload a CSV of transactions. Automatically detect required reports and generate draft LCTRs, LVCTRs, EFTRs, and STRs with AI-powered analysis.

AI-Driven STR Detection

Our proprietary aiSTR™ technology automatically flags high-risk transactions and drafts narratives aligned with FINTRAC risk indicators. You retain full control with manual overrides.

Customer & Location Management

Maintain complete customer and location data with direct integrations to providers like SumSub. Reports auto-populate with existing records.

Draft & Save Reports

Create and save draft reports — including AI-generated STR narratives — for later completion. Work at your own pace with automatic data preservation.

STR Extensions Made Simple

Add STR extensions to existing reports (LCTR/LVCTR/EFTR/CDR) with one click. Fill only additional fields — no separate forms.

COMING SOON

AI Model Configuration

Risk Detection Settings

Risk Indicator A
Identified: 87%
Risk Indicator B
Identified: 94%
Risk Indicator C
Identified: 82%
Overall Risk Rating78%

Recommended STR filing

aiSTR 2.0

Advanced risk flagging via AI. Machine learning flags suspicious transaction patterns — reducing false positives and helping teams act faster on STRs.

Direct Slack integration for no login STR review/submissions

Maximize risk detection with custom set, and AI-driven risk indicators

Set your risk indicator weightings, or let aiSTR optimize detection

Generate higher accuracy through reinforced learning

30-Minute Demo

FINTRAC Compliance for Mortgage Professionals

In 30 minutes, walk through how Comply+ helps you move from transaction data to draft reports, STR review with your team, and FINTRAC API submission without logging into the Web Reporting System (FWR) for each filing.

1. Draft report preparation

Upload a CSV or connect your system and see how Comply+ helps surface reportable activity for LCTR, LVCTR, EFTR, and CDR workflows.

2. STR review path

See how aiSTR™ supports narrative drafts and how your team reviews and decides what is filed.

3. Submit and confirm

Follow submission through FINTRAC's API and where confirmations and status live in Comply+.

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Disclaimer

This page is provided for general informational purposes only and reflects our interpretation and opinions based on publicly available information at the time of writing. It does not constitute legal advice, financial advice, regulatory guidance, or a substitute for professional counsel. Reporting entities and businesses subject to FINTRAC obligations should consult qualified legal and compliance advisors before making decisions relating to FINTRAC, AML obligations, or compliance requirements.