The Financial Transactions and Reports Analysis Centre of Canada has published guidance confirming that title insurers will be subject to anti-money laundering and anti-terrorist financing obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its Regulations effective 1 October 2025. FINTRAC also indicated that, in the first year after the regulations come into force, it will place emphasis on engagement, outreach and guidance to support awareness and understanding among new reporting entities. The guidance sets expectations that title insurers implement a compliance program, verify the identity of persons and entities for certain activities and transactions using prescribed methods, and apply business relationship and ongoing monitoring requirements once a business relationship is established. It also outlines reporting obligations, including Suspicious Transaction Reports, Listed Person or Entity Property Reports, and reporting suspected sanctions evasion, as well as record-keeping requirements and the application of ministerial directives and transaction restrictions. FINTRAC noted it may conduct compliance examinations covering areas such as compliance program implementation, required transaction reporting, client identification and record keeping, and that it has authority to issue administrative monetary penalties for non-compliance.

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