Canada's New Sanctioned Property Reporting Regime Now In Force

On February 28, 2025, the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC") released guidance (the "Guidance") and forms of reports (the "Forms") for the new sanctions reporting obligation imposed by amendments (the "Amendments") to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA") and the Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations (the "STR Regulations") issued thereunder. As discussed in our client alert last year when a draft of the Amendments was first released for public consultation, Evasive Maneuvers – New Reporting Obligations and Enforcement Tools for Canada's Economic Sanctions Regime, the Amendments greatly expand the existing reporting requirements under the STR Regulations to require regulated entities to report on property directly or indirectly owned or controlled by sanctioned persons (the "Reporting Obligation").