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ARTICLE · 16 MARCH 2009

New Record-Keeping And Reporting Obligations In Effect For Real Estate Developers

McMillan LLP
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On December 14, 2006, Bill C-25 (the “Bill”) received Royal Assent. The Bill is intended to bolster the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the “Act”) and harmonize it with current international standards as well as with the recommendations of the intergovernmental Financial Action Task Force on Money Laundering.

CanadaReal Estate and Construction

Background to Bill C-25

On December 14, 2006, Bill C-25 (the "Bill") received Royal Assent. The Bill is intended to bolster the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the "Act") and harmonize it with current international standards as well as with the recommendations of the intergovernmental Financial Action Task Force on Money Laundering.

The Bill's provisions have come into force in phases over 2008 and 2009. In particular, as of February 20, 2009, real estate developers are subject to this regime as reporting entities.

The Act and its regulations require such entities to create a compliance regime, identify clients, keep specified records, and make reports concerning certain transactions to the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC").

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