FINTRAC Compliance Checklist for BC Realtors (2026)

What Is FINTRAC and Why Does It Matter?

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada's financial intelligence unit. Established in 2000, FINTRAC operates under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) to detect and prevent money laundering and terrorist financing in Canada.

Real estate has been identified globally as one of the highest-risk sectors for money laundering. British Columbia specifically has received significant attention following the 2019 Cullen Commission of Inquiry into Money Laundering, which found that billions of dollars in illicit funds had been laundered through BC real estate. As a result, compliance requirements for BC real estate professionals are among the strictest in Canada.

As a licensed real estate agent in BC, you are a "reporting entity" under the PCMLTFA. This means you have specific legal obligations to identify your clients, keep records, report certain transactions, and implement a compliance program. These are not guidelines -- they are legal requirements, and ignorance is not a defence.

Who Must Comply

Every person and entity engaged in the business of real estate is a reporting entity under the PCMLTFA. In practical terms, this includes:

• Licensed real estate agents and associate brokers
• Managing brokers and brokerages
• Real estate developers who sell directly to the public
• Any person acting as an agent or mandatary in the sale of real estate

Your brokerage is responsible for having an overall compliance program, but as an individual licensee, you are personally responsible for meeting your obligations on each transaction. If you fail to verify a client's identity, the penalty applies to you -- not just your brokerage.

Client Identification Requirements

The cornerstone of FINTRAC compliance is verifying the identity of your client. You must verify the identity of every person for whom you act as an agent in a real estate transaction. Here is exactly what you need to collect:

For Individual Clients

Acceptable Government-Issued Photo ID

• Canadian passport
• Canadian driver's licence (any province)
• BC Services Card (photo version) or BCID
• Canadian citizenship card (with photo)
• Permanent resident card
• Foreign passport (for non-Canadian clients)

The identification must be valid and unexpired. You must see the original document in person -- photocopies, scans, and photos on a phone screen are not acceptable for in-person verification. If verifying remotely (non-face-to-face), FINTRAC allows dual-process verification using two forms of identification from reliable sources, or a credit file from a Canadian credit bureau.

For Corporate Clients

When your client is a corporation, you must verify the existence of the corporation and identify all directors. This requires:

• Full legal name of the corporation
• Incorporation number and jurisdiction
• Address of principal place of business
• Names of all directors
• Verification through a corporate registry search (BC Online or Corporations Canada)
• Individual identification of the person acting on behalf of the corporation

Beneficial Ownership

Beyond identifying your client, you must make reasonable efforts to determine the beneficial ownership of the property. This means identifying any person or entity that owns or controls 25% or more of the entity purchasing the property, or any person on whose behalf the transaction is conducted.

BC has additional beneficial ownership disclosure requirements under the Land Owner Transparency Act (LOTA). Since November 2020, any interest holder who is a "reporting body" (corporation, trustee, or partner) must file a transparency report with the Land Title Office disclosing all beneficial owners.

Source of Funds

While FINTRAC does not explicitly require real estate agents to document the source of funds for every transaction, you are expected to understand where the money is coming from as part of your "know your client" obligations. This is particularly important when the funds do not come from obvious sources like a mortgage or the sale of another property.

Questions you should be able to answer about your client:

• How is the purchase being financed? (mortgage, cash, combination)
• Where is the deposit coming from? (personal savings, gift, proceeds of sale)
• Is a third party providing any funds? If so, who and what is their relationship?
• Does the purchase price align with the client's stated income and occupation?

You do not need to verify bank statements or demand proof of funds as a matter of course. But if the answers to these questions raise concerns -- for example, a first-time buyer with a modest income making a cash offer on a $3 million property -- you should ask follow-up questions and consider whether an STR is warranted.

Reporting Obligations: STR and LCTR

Suspicious Transaction Report (STR)

You must file a Suspicious Transaction Report with FINTRAC if you have reasonable grounds to suspect that a transaction (or attempted transaction) is related to the commission or attempted commission of a money laundering or terrorist financing offence. The key word is "reasonable grounds to suspect" -- you do not need proof or certainty.

Common indicators that may trigger an STR:

• Client reluctant to provide identification or gives inconsistent information
• Purchase price significantly above or below market value with no explanation
• All-cash purchase with no clear source of funds
• Multiple transactions in a short period to split amounts below thresholds
• Client acting on behalf of undisclosed third parties
• Property purchased and quickly resold at inflated prices ("property flipping")
• Client not concerned about price, terms, or property condition
• Use of nominees, shell companies, or trusts without clear business rationale
• Client from a jurisdiction with weak anti-money laundering controls
• Unusual urgency to close without normal due diligence

Large Cash Transaction Report (LCTR)

You must file a Large Cash Transaction Report if you receive $10,000 or more in cash (physical currency) in a single transaction or in multiple transactions within a 24-hour period from the same client. The LCTR must be filed within 15 calendar days.

In practice, most real estate transactions in BC do not involve large cash payments. Deposits are typically paid by cheque, bank draft, or wire transfer. However, if a client offers to pay any portion in cash, you should be aware of the reporting requirement and the associated red flags.

Record Retention Requirements

FINTRAC requires you to retain the following records for at least 5 years from the date the transaction was completed:

Note that BCFSA requires 7-year retention of all transaction files under the Real Estate Services Rules. Since BCFSA's requirement is longer, most BC agents default to 7-year retention for all records, which satisfies both FINTRAC and BCFSA.

Penalties for Non-Compliance

FINTRAC has the authority to impose both administrative monetary penalties (AMPs) and criminal penalties. The range is significant:

Beyond the direct financial penalties, FINTRAC publishes the names of all entities penalized on its website. For a real estate agent, this public disclosure can be devastating to your reputation and career. Insurance coverage typically does not cover FINTRAC penalties, and your brokerage may terminate your licence agreement if you are found non-compliant.

10-Step FINTRAC Compliance Checklist

Use this checklist on every transaction to ensure full compliance:

BC-Specific Considerations

British Columbia has additional anti-money laundering measures that go beyond the federal FINTRAC requirements:

• Land Owner Transparency Act (LOTA): Requires disclosure of beneficial owners for all corporate, trust, and partnership interests in BC real property. Penalties for non-compliance include fines up to $50,000 for individuals and $100,000 for corporations.
• Speculation and Vacancy Tax: Annual tax on vacant properties in designated areas. While not directly a FINTRAC issue, the declaration process helps identify ownership patterns that may indicate money laundering.
• Property Transfer Tax (PTT) audits: The BC government uses PTT data to identify properties purchased with no apparent legitimate source of funds.
• Cullen Commission recommendations: Several recommendations from the 2022 final report are being implemented progressively, including enhanced information sharing between regulators and strengthened enforcement capacity.
• Unexplained Wealth Orders (UWOs): BC was the first province to introduce UWOs, which allow the government to freeze and potentially seize property where the owner cannot explain how it was acquired.

Frequently Asked Questions