Title Insurers Guide to FINTRAC Compliance 2025

Starting October 1, 2025, title insurers must comply with Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), as outlined by FINTRAC. These rules target anti-money laundering (AML) and anti-terrorist financing (ATF) efforts. Here’s what you need to know:

Who’s Affected?

Title insurers providing policies for real property purchasers, as defined by the Insurance Companies Act, are considered reporting entities.

Core Requirements

• Compliance Program: Establish policies, appoint a compliance officer, and train staff.
• Know Your Client (KYC): Verify client identities and monitor business relationships.
• Reporting: Submit Suspicious Transaction Reports and Listed Person/Entity Property Reports to FINTRAC.
• Record Keeping: Maintain detailed transaction and client records.
• Ministerial Directives: Follow any issued directives or restrictions.

FINTRAC’s Focus

In the first year, FINTRAC will emphasize guidance and outreach to help title insurers comply. Assessments may review your compliance program, reports, and records. Non-compliance could lead to penalties.

How to Prepare

• Build a robust compliance program.
• Train employees on reporting suspicious transactions.
• Set up KYC and record-keeping systems.
• Stay updated via FINTRAC’s website.

For details, check FINTRAC’s official guidance.