FINTRAC Updated Guidance on Client ID & Record Keeping 

New Regulations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) in relation to client identification came into force on October 1, 2025. The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) updated its guidance on the use of an agent or mandatary and its guidance on unrepresented parties in real estate transactions. 

Key changes to identity verification

Starting October 1, 2025, businesses subject to the Act can use an agent or a mandatary to verify the identity of a corporation or an entity on their behalf. Prior to October 1, 2025, using an agent or a mandatary could only be relied on when verifying the identity of a person. 

As outlined in FINTRAC’s updated guidance, reporting entities must follow stricter protocols when verifying the identity of individuals and entities.  

For more information, refer to FINTRAC’s guidance: Methods to verify the identity of persons and entities. 

Record keeping requirements 

Starting October 1, 2025, real estate licensees must verify the identity of unrepresented parties, i.e., any party who takes part in a purchase or sale of real estate and is not represented by a real estate broker or sales representative. Licensees must keep an information record on unrepresented parties and make the associated third-party determination for these parties in real estate transactions. 

According to FINTRAC’s recordkeeping guidance, licensees must maintain detailed records for five years. Key updates include: 

Required records 

• Suspicious Transaction Reports (STRs): Must retain copies for five years. 
• Large Cash & Virtual Currency Transaction Records: Required when receiving $10,000+ in cash or equivalent virtual currency. 
• Receipt of Funds Records: Must include detailed client and transaction information, even for small amounts. 
• Information Records: Required for each client involved in a transaction, including corporate documents for entities. 
• Unrepresented Party Identification: Licensees must take reasonable steps to verify identity and document efforts if unsuccessful. 

Exceptions

• Records are not required for transactions involving financial entities, public bodies, or very large corporations/trusts. 

For more information, refer to FINTRAC’s guidelines:  

• When to verify the identity of persons and entities – Real estate brokers or sales representatives, and real estate developers and, 
• Record keeping requirements for real estate brokers or sales representatives, and real estate developers  

Additional information on changes to the PCMLTFA and its Regulations can be found at these resources: 

• Amendments to PCMLTFA Regulations: Canada Gazette, Part 2, Volume 159, Number 7: Regulations Amending the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations and the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations 
• BCFSA Advisory (June 10, 2025): Amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations – New Information Sharing Provisions for Reporting Entities.  

For questions related to this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.