The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) published compliance guidance on beneficial ownership requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations, including a new obligation from 1 October 2025 to consult Corporations Canada’s database for certain high-risk corporations and to report material discrepancies. The guidance applies to all reporting entities except title insurers and reiterates that beneficial owners are natural persons who directly or indirectly own or control 25% or more of an entity, with specific definitions for trusts and widely held or publicly traded trusts. For corporations incorporated under the Canada Business Corporations Act that are assessed as high risk, reporting entities must consult Corporations Canada’s database when high risk is first determined and during ongoing monitoring, compare the results to the beneficial ownership information obtained, and identify any material discrepancy that could affect proper identification or conceal individuals with control. If a material discrepancy is identified and not resolved within 30 days, it must be reported to Corporations Canada within 30 days of identification, while reporting is voluntary for non-high-risk CBCA corporations; acknowledgement notices must be retained for five years. The guidance also sets out recordkeeping expectations, describes steps to take when beneficial ownership information cannot be obtained or confirmed (including reasonable measures to verify the entity’s chief executive officer or equivalent and applying special measures for high-risk clients), and notes specified circumstances where beneficial ownership requirements do not apply.
Financial Transactions and Reports Analysis Centre of Canada 2025-10-01
Financial Transactions and Reports Analysis Centre of Canada requires Corporations Canada database checks and discrepancy reporting for high-risk CBCA corporations from 1 October 2025
FINTRAC issued compliance guidance on beneficial ownership under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, mandating consultation of Corporations Canada’s database for high-risk corporations. Reporting entities must identify and report material discrepancies within 30 days, with voluntary reporting for non-high-risk corporations. The guidance outlines recordkeeping, verification measures, and exceptions to beneficial ownership requirements.