For years, most Canadian businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) have met their obligations without ever formally signing up with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
According to Alessa, that is about to change. Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, received Royal Assent on 26 March 2026. It introduces mandatory registration, known as enrolment, along with periodic renewal and the risk of having that enrolment revoked.
At present, only domestic and foreign money services businesses (MSBs) must register with FINTRAC before operating. Every other reporting entity carries PCMLTFA duties without a formal enrolment process. Bill C-12 inserts sections 11.4001 to 11.4015 into the Act, requiring every person or entity covered by section 5 to enrol, subject to limited exceptions.
That scope spans financial entities, securities dealers, casinos, real estate brokers and accountants. Individuals acting solely as employees or agents of another reporting entity are exempt, and already-registered MSBs will not need to enrol twice. FINTRAC will also maintain a public roll of enrolled entities, sharply increasing supervisory visibility.
Timing remains open. Universal enrolment will take effect once regulations are published in the Canada Gazette, Part II, so firms are in a preparation window rather than facing a filing deadline. Other parts of Bill C-12 already apply, including a new administrative monetary penalty (AMP) framework and a requirement for compliance programmes that are reasonably designed, risk-based and effective, both in force from 26 March 2026.
The enrolment lifecycle covers applications in a prescribed form, renewal before expiry, notification of changes within 30 days, and responses to FINTRAC information requests. FINTRAC can deny or revoke enrolment, with review and appeal rights to the Federal Court.
Legal analysis suggests revocation could follow if an entity fails to answer an information request within 30 days, or if it commits a violation and does not pay the resulting penalty. For many businesses, losing enrolment could disrupt operations.
The stakes are rising elsewhere too. According to FINTRAC, maximum AMPs will increase to as much as 40 times current limits. BLG’s analysis puts the new ceilings at C$40,000 for minor violations, C$4m for serious violations and C$20m for very serious ones.
FINTRAC will also weigh ability to pay, impose mandatory compliance agreements for prescribed breaches and use publishable compliance orders, with breaching an order counting as a separate violation.
Firms can act now by confirming their reporting entity status, assigning a named owner and backup for enrolment tasks, gathering core business information, building a 30-day response process for regulator correspondence, testing their compliance programme and tracking FINTRAC updates.
Enrolment transforms quiet compliance into an ongoing regulatory relationship, rewarding organisations with clear ownership and well-organised records.
Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
