FINTRAC Rules On The Horizon

Effective October 2025, securities dealers and advisers will have new anti-money laundering obligations with respect to any client that is at high risk for a money laundering or terrorist activity financing offence, if that client is also incorporated or continued under the Canada Business Corporations Act (CBCA).

The securities dealer or adviser will be required to cross reference the beneficial ownership information provided by the client and maintained in its records against the federal government's beneficial ownership registry and report material discrepancies.

As a reminder, under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, dealers and portfolio managers are required to conduct a risk assessment of clients to determine if there is a risk of a money laundering or terrorist activity financing offence. Under existing expectations, the firm is then expected to conduct risk mitigation measures with respect to the client, with the nature