Financial Transactions and Reports Analysis Centre of Canada issues guidance on anti-money laundering obligations for financing and leasing entities effective April 1 2025

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) published guidance for financing or leasing entities setting out when they are subject to Canada’s anti-money laundering and anti-terrorist financing regime and the core compliance obligations they must meet, effective April 1, 2025. The guidance explains that a financing or leasing entity is a person or entity engaged in the business of financing or leasing, and becomes subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations when it finances or leases property for business purposes (other than real property or immovables), property valued at CAD 100,000 or more (other than real property or immovables), or passenger vehicles in Canada. It summarises requirements to implement a compliance program, conduct know-your-client measures, report transactions, keep records, and apply ministerial directives. FINTRAC also highlights its compliance examination authority and areas of review, including transaction reporting, client identification, record keeping, and third-party determination, and notes it can issue administrative monetary penalties for non-compliance. FINTRAC states that during the first year after the obligations come into force it will prioritise engagement, outreach and guidance for new reporting entities, including industry consultation to develop guidance to support implementation and maturing of compliance programs.