Ontario Brokerages and Developers
Five things FINTRAC expects of brokerages and developers, the penalty scale since 26 March 2026, and recent penalties.
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You are already a reporting entity
Whether or not you have ever filed a report, the PCMLTFA already applies to your firm. Since 26 March 2026 the cost of getting it wrong has risen by up to 40 times, and universal enrolment with FINTRAC is on the way.
What you owe
Five things FINTRAC expects, whatever the size of the firm
A compliance program that works
Compliance officer, written policies, a documented risk assessment, training, and an independent review every two years. Since 26 March 2026 the program must be reasonably designed, risk-based and effective, so a binder on a shelf no longer passes.
Knowing who you are dealing with
Verify identity, collect beneficial ownership for entity clients, make the third party determination, check for politically exposed persons. Since 1 October 2025 this extends to unrepresented buyers and sellers.
Four reports, and the judgment behind them
Suspicious transactions, including attempted ones. Cash or virtual currency of $10,000 or more, including amounts within 24 hours. Property of a listed person, immediately. STR duty binds the individual rep as well as the brokerage.
Records that survive an examination
Receipt of funds records, client identification and information records, beneficial ownership records, and copies of every report filed. Generally five years.
Enrolment, once the regulations land
Every brokerage and developer will have to enrol with FINTRAC for the first time, on terms set by regulations still to be published in the Canada Gazette.
What it costs
The failures FINTRAC penalizes are basic program gaps. Across the public notices, the recurring failures are the same: no documented risk assessment, policies that are not current or not approved by a senior officer, weak training, and missed suspicious transaction reports.
Maximum penalty per violation for a business: FINTRAC's stated increase of up to 40 times, from 26 March 2026, applied to the previous maximum beneath each figure. Some program violations moved up to very serious, and every penalty now comes with a compliance agreement.
Recent penalties, all set under the old scale
How ComplyFactor helps
Seven pieces of work, in an examiner's order.
Risk assessment
Documented and defensible, covering clients, geography, property types, delivery channels and new developments.
Policies and procedures
Real estate specific, approved by a senior officer, current with the October 2025 rules.
Two-year effectiveness review
Independent review run against FINTRAC's own examination approach.
Agent training
Annual sessions for brokers and reps, built around FINTRAC's real estate indicators.
STR support
Case review and report drafting for escalated files, so the call is made and recorded.
Enrolment readiness
Ready to file the day the enrolment regulations are published.
Examination preparation
A mock examination and a remediation plan, which matters more now that every penalty carries a mandatory compliance agreement.
Start with a gap check
A short review of your current program against the March 2026 standard, with a written list of what an examiner would ask for first.
contact@complyfactor.com · +1 807 806 0444
Sources: FINTRAC public notices of administrative monetary penalties, May 2025 to July 2026; FINTRAC real estate guidance, penalty policy and changes page. ComplyFactor Real Estate Leave-Behind, current to 1 October 2026.
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