On November 20th, 2025 FINTRAC announced that it imposed five administrative monetary penalties (AMPs) on real-estate brokerages across Canada for violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). The penalties span British Columbia, Alberta, Ontario, and Québec, underscoring a simple reality: real estate is now firmly in FINTRAC’s enforcement spotlight.
The Brokerages Penalized
Five firms were named, with penalties ranging from $23,100 to $149,886. Some have paid in full; others are appealing. Issues cited include failures in:
- Client identification
- Beneficial ownership verification
- Compliance program implementation
- Ongoing monitoring
- Recordkeeping documentation
These are foundational PCMLTFA obligations that every real-estate compliance program must meet.
Why This Matters for Real-Estate Compliance Teams
- Regulatory attention is escalating
FINTRAC’s enforcement actions show that exams are increasing in frequency and depth. For years, real estate was seen as lower-priority when compared to banks or MSBs. That era is over.
This batch of penalties demonstrates consistent enforcement across multiple provinces, not isolated cases.
- Documentation gaps are a risk
The penalties were largely tied to missing or incomplete records. This shows that FINTRAC continues to emphasize that if it isn’t documented, it didn’t happen.
- Beneficial ownership and ongoing monitoring remain weak points
Across the sector, many firms continue to struggle with verifying ownership structures and applying risk-based monitoring. These are two areas FINTRAC repeatedly flags.
- Public naming carries reputational risk
Beyond financial penalties, every AMP is posted publicly. This affects client trust, business relationships, and internal morale. For many firms, the reputational impact can exceed the cost of the fine.
What Compliance Teams Should Do Now
If you oversee compliance for a brokerage, the latest penalties are a clear reminder to audit your program. Focus on strengthening:
Client Identification & Verification: Ensure all required documents are collected, validated, and stored consistently.
Beneficial Ownership: Confirm controlling individuals and keep your documentation current.
Risk-Based Assessments: Your policies must describe how you assess risk, how you rank clients, and how monitoring intensity changes with risk level.
Ongoing Monitoring & Recordkeeping: Build workflows to ensure monitoring activities are performed and fully documented. Missing notes, incomplete logs, or gaps in review intervals are key FINTRAC triggers.
Training & Staff Awareness: FINTRAC expects staff to understand obligations, red flags, and how to escalate issues. Annual training alone may not be enough.
Digital Tools & Automation: Manual processes lead to inconsistency and missing information. Consider using compliance platforms that support beneficial-ownership screening, PEP screening, adverse media searches, centralized documentation, and ongoing monitoring workflows.
Solutions like Alessa can bring these capabilities together in one platform or provide a single solution such as sanctions screening, EDD or transaction monitoring to help fill compliance gaps.
The Bigger Picture: A Sector in Transition
Real-estate professionals increasingly face the same expectations as large financial institutions. As the sector matures under the PCMLTFA, FINTRAC will likely continue to:
- Expand exams
- Standardize expectations
- Conduct deeper reviews of documentation quality
- Name non-compliant firms publicly
Compliance teams that move from reactive to proactive will be best positioned to avoid disruptions as they will be able to demonstrate to regulators that they take AML obligations seriously.
The message from FINTRAC is clear: the real-estate sector is now a fully active regulatory priority.
The five penalties issued this month should be viewed not as isolated incidents, but as a signal of continuing scrutiny.
Now is the right time for compliance teams to strengthen policies, tighten documentation, and modernize monitoring practices.
Alessa