FINTRAC Compliance for Real Estate

Why Real Estate Professionals Have FINTRAC Obligations

Real estate is a high-value target for money laundering in Canada. FINTRAC has made that clear through a steady increase in enforcement actions against brokerages and agents who fall short of their compliance obligations. Recent penalties against Century 21 Heritage Group and Manor Windsor Realty highlight how seriously FINTRAC treats non-compliance in this sector.

Under the PCMLTFA, real estate brokers, sales representatives, and developers are reporting entities when they act as agents in the purchase or sale of real estate. That means obligations around client identification, record-keeping, suspicious transaction reporting, and compliance program maintenance apply to every qualifying transaction.

What Triggers Your Obligations

Your FINTRAC obligations are activated when you are involved in the purchase or sale of real estate. Specifically:

• Receipt of funds records: You must create a receipt of funds record every time you receive funds in any amount in the course of a real estate transaction. The record must document how the funds were received (cash, cheque, wire, etc.), the amount, and the identity of the person or entity providing them. This applies to every payment, regardless of size.
• Large Cash Transaction Reports (LCTR): If you receive $10,000 or more in cash in a single transaction or in multiple cash payments totalling $10,000+ within 24 hours related to the same transaction, you must file an LCTR with FINTRAC within 15 calendar days.
• Large Virtual Currency Transaction Reports (LVCTR): If you receive virtual currency equivalent to $10,000 or more in a single transaction, you must file an LVCTR with FINTRAC within 5 working days.
• Suspicious Transaction Reports (STR): You must file an STR if you have reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing. There is no dollar threshold. In real estate, red flags include buyers who insist on paying large portions in cash, transactions involving shell companies with unclear beneficial ownership, rapid resale of properties at inflated prices, and purchases that seem inconsistent with the buyer's financial profile.
• Listed Person or Entity Property Reports: If you know that property in your possession or control is owned or controlled by a listed person or entity under the Criminal Code, the United Nations Act, or the Special Economic Measures Act, you must file a report immediately.

Common Compliance Pain Points

• Decentralized agent activity: Brokerages manage dozens or hundreds of agents, each handling their own transactions. Ensuring every agent properly identifies clients, creates receipt of funds records, and flags suspicious activity requires strong centralized oversight.
• Receipt of funds tracking: Unlike most industries, real estate professionals must create a receipt of funds record for every payment received, regardless of amount. Every deposit, every cheque, every wire transfer in a real estate deal must be documented with the correct identification and transaction information. Missing a single record is a compliance gap.
• Recognizing suspicious activity: Real estate transactions are complex. Agents are focused on closing deals, not analyzing whether a buyer's funding structure raises money laundering concerns. Without clear guidance and tools, STR obligations often go unmet.
• Maintaining records for five years: FINTRAC requires records to be kept for at least five years after the transaction. For high-volume brokerages, that means managing a growing archive of client identification, receipt of funds records, and transaction documentation.
• Compliance program requirements: Every real estate brokerage needs a written compliance program that includes policies and procedures, a compliance officer, a risk assessment, and an ongoing training plan. Many smaller brokerages struggle to build and maintain this infrastructure.

How Comply+ Works for Real Estate

Automated Receipt of Funds Records

Input your transaction data and Comply+ generates receipt of funds records for every payment received. Client identification fields are auto-populated from your existing records, and the system prompts you for any missing information.

LCTR Detection and Filing

Comply+ monitors for cash transactions at or above the $10,000 threshold. When a reportable transaction is detected, the system generates a pre-filled LCTR and submits it directly to FINTRAC on your behalf.

STR Detection with AI

Our aiSTR technology flags transactions that match FINTRAC's real estate risk indicators: unusual payment structures, mismatches between purchase price and apparent buyer resources, rapid property flipping patterns, and transactions involving high-risk jurisdictions. Each flag comes with a draft narrative you can review before submission.

Centralized Compliance for Multi-Agent Brokerages

Whether you have 5 agents or 500, Comply+ gives your compliance officer a single dashboard to track all reporting obligations across the brokerage. No more chasing individual agents for documentation.

Record Keeping Requirements

FINTRAC publishes official guidance on record keeping for real estate brokers or sales representatives, and real estate developers. For full details and current requirements, see: Record keeping requirements for real estate brokers or sales representatives, and real estate developers (FINTRAC).