Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Canada — Quebec CA-QC

Domains covered
8 of 8
Sources
141
Role actions
8
Horizon <90d
0
Jurisdiction profile
FATF status: Compliant Tier: A Risk direction: Stable Enablement vs enforcement: Mixed

Quebec operates under Canada's federal PCMLTFA/FINTRAC regime plus its own civil-law notarial system and provincial securities regulator (AMF Québec).

MoreA 2015 Supreme Court ruling excludes legal counsels, legal firms and Quebec notaries from AML/CFT supervision, leaving conveyancing, incorporation and trust work largely outside FINTRAC's reach. Federal crypto/MSB oversight is comparatively mature and enforcement-active, but real estate, casino and DNFBP supervision remain uneven.

Key deficiencies
  • Constitutional carve-out excluding Quebec notaries and legal counsel from AML/CFT reporting obligations
  • FINTRAC cannot compel additional information from reporting entities beyond voluntary submissions
  • Uneven, historically low STR filing in real estate and DNFBP sectors; Montreal named as a laundering hub
  • Federal-provincial fragmentation of beneficial ownership registries; Quebec's provincial registrar sits outside the federal CBCA registry
Recent developments (18m)
  • FINTRAC's record ~CAD $176M penalty against Xeltox Enterprises Ltd. (Cryptomus), Oct 2025
  • FINTRAC revocation of roughly 35 crypto money-service-business registrations (2025-2026)
  • Canada's Nov 2025 SEMA sanctions on Russian drone makers and 100 shadow-fleet vessels
  • Multi-agency crypto-fraud disruption operations (Project Atlas / Operation Avalanche) involving AMF Québec, Aug 2025
  • FATF 5th-round effectiveness Mutual Evaluation of Canada entering its indicative onsite/Plenary cycle

Canada federal law that applies in Canada – Quebec is covered once, on the Canada page. This page covers Canada – Quebec’s own layer: its own law, regulators and enforcement.

Brief

Lead signal

Lead Signal

Canada's latest FATF Mutual Evaluation Report, assessing the national anti-money-laundering regime, singles out Quebec's beneficial-ownership infrastructure as a point of relative strength within an otherwise critical national assessment. The report cites the Registraire des entreprises (REQ) public beneficial-ownership register, in force for ultimate-beneficiary disclosure since 31 March 2023 and searchable by name since 31 July 2024, as a corporate-transparency advance. This finding currently rests on secondary reporting describing the FATF document rather than on the Mutual Evaluation Report text itself, and is treated as probable rather than confirmed pending direct retrieval of the primary FATF instrument.

Read full brief

Lead Signal

Canada's latest FATF Mutual Evaluation Report, assessing the national anti-money-laundering regime, singles out Quebec's beneficial-ownership infrastructure as a point of relative strength within an otherwise critical national assessment. The report cites the Registraire des entreprises (REQ) public beneficial-ownership register, in force for ultimate-beneficiary disclosure since 31 March 2023 and searchable by name since 31 July 2024, as a corporate-transparency advance. This finding currently rests on secondary reporting describing the FATF document rather than on the Mutual Evaluation Report text itself, and is treated as probable rather than confirmed pending direct retrieval of the primary FATF instrument.

The REQ register predates and, in terms of public searchability, exceeds the federal Canada Business Corporations Act significant-control-person regime that applies to federally incorporated entities. Quebec's framework derives from the Act respecting the legal publicity of enterprises as amended by Bill 78, which introduced ultimate-beneficiary disclosure obligations ahead of comparable developments in several other Canadian provinces. The FATF citation gives this structural feature external validation at a moment when Canada's overall mutual evaluation outcome has been otherwise unfavourable on professional money-laundering gatekeeping.

Other Developments

No material movement elsewhere in the eight-domain spine. Sanctions administration, enabler-jurisdiction exposure, conflict finance, crypto and digital-asset integrity, compliance technology, the AML/CTF supervisory architecture, and commercial activity among integrity-infrastructure firms all remain stable for Quebec this cycle. FINTRAC continues as the federal AML/CTF supervisor for reporting entities located in or operating into Quebec, with the Autorite des marches financiers retaining provincial conduct supervision but no standalone provincial AML statute. Tier D jurisdictions were not reached this cycle, reflecting a deliberate concentration of research budget on the bound jurisdiction rather than a finding of stability elsewhere.

Cross-Monitor Connections

The REQ beneficial-ownership finding sits adjacent to corporate-registry and transparency questions tracked by other monitors assessing company-formation and ownership-disclosure regimes, though no cross-monitor overlap was flagged in the structured input for this cycle.

Outlook

The REQ register's standing as a FATF-cited corporate-transparency advance is likely to remain the principal Quebec-specific reference point in beneficial-ownership discussions until the Mutual Evaluation Report itself is retrieved and the finding can be upgraded from probable to confirmed. Absent a new structural development, the other seven domains are expected to remain stable for Quebec, with federal-layer sanctions and AML/CTF architecture continuing to set the operative framework within which Quebec entities are supervised.

Earlier periodic briefs (4)
25 Oct 2026 · fim-2026-10-25

Lead Signal

Canada's latest FATF Mutual Evaluation Report, assessing the national anti-money-laundering regime, singles out Quebec's beneficial-ownership infrastructure as a point of relative strength within an otherwise critical national assessment. The report cites the Registraire des entreprises (REQ) public beneficial-ownership register, in force for ultimate-beneficiary disclosure since 31 March 2023 and searchable by name since 31 July 2024, as a corporate-transparency advance. This finding currently rests on secondary reporting describing the FATF document rather than on the Mutual Evaluation Report text itself, and is treated as probable rather than confirmed pending direct retrieval of the primary FATF instrument.

The REQ register predates and, in terms of public searchability, exceeds the federal Canada Business Corporations Act significant-control-person regime that applies to federally incorporated entities. Quebec's framework derives from the Act respecting the legal publicity of enterprises as amended by Bill 78, which introduced ultimate-beneficiary disclosure obligations ahead of comparable developments in several other Canadian provinces. The FATF citation gives this structural feature external validation at a moment when Canada's overall mutual evaluation outcome has been otherwise unfavourable on professional money-laundering gatekeeping.

Other Developments

No material movement elsewhere in the eight-domain spine. Sanctions administration, enabler-jurisdiction exposure, conflict finance, crypto and digital-asset integrity, compliance technology, the AML/CTF supervisory architecture, and commercial activity among integrity-infrastructure firms all remain stable for Quebec. FINTRAC continues as the federal AML/CTF supervisor for reporting entities located in or operating into Quebec, with the Autorite des marches financiers retaining provincial conduct supervision but no standalone provincial AML statute. Tier D jurisdictions were not reached, reflecting a deliberate concentration of research budget on the bound jurisdiction rather than a finding of stability elsewhere.

Cross-Monitor Connections

The REQ beneficial-ownership finding sits adjacent to corporate-registry and transparency questions tracked by other monitors assessing company-formation and ownership-disclosure regimes, though no cross-monitor overlap was flagged in the structured input.

Outlook

The REQ register's standing as a FATF-cited corporate-transparency advance is likely to remain the principal Quebec-specific reference point in beneficial-ownership discussions until the Mutual Evaluation Report itself is retrieved and the finding can be upgraded from probable to confirmed. Absent a new structural development, the other seven domains are expected to remain stable for Quebec, with federal-layer sanctions and AML/CTF architecture continuing to set the operative framework within which Quebec entities are supervised.

11 Oct 2026 · fim-2026-10-11

Lead Signal

The principal development touching Quebec this cycle sits at the federal layer and inherits downward: the Financial Action Task Force and the Asia/Pacific Group adopted Canada's 2026 Mutual Evaluation Report, moving Canada from enhanced to regular follow-up without a grey-listing, and crediting progress on beneficial-ownership transparency. Quebec carries no independent finding of its own this cycle that clears the materiality bar on a standalone basis, but the federal evaluation reaches the province through standard chain-parent inheritance, and a province-specific thread sits directly inside that inheritance: Quebec's Registraire des entreprises ultimate-beneficiary register, amended under Bill 78 with effect from 31 March 2023, is cited in commentary as part of the architecture the evaluators had in view.

Other Developments

Beneficial-ownership register comparison. Quebec's REQ register is described in law-firm commentary as freely and publicly searchable, a broader public-access posture than the federal Canada Business Corporations Act register, though it retains a twenty-five percent control threshold for identifying a beneficial owner and no independent verification of filer-submitted data. This characterization rests on a single tier-three secondary source rather than a primary statement from the Registraire or the Commission d'acces a l'information, which caps the finding at a probable rather than confirmed tier even though the underlying federal FATF finding itself is tier-one confirmed.

Crypto enforcement posture, standing context. A Tribunal administratif des marches financiers ruling, reported through tier-three commentary and dated outside the present reporting window, held that digital-asset tokens traded on decentralized exchanges did not satisfy the investment-contract test, reasoning drawn in part from the United States Ripple decision, while separately upholding findings of unregistered-securities sales conducted through a pump-and-dump scheme. This is carried forward as standing context relevant to the crypto domain rather than as a new finding, since the decision predates this cycle and the underlying ruling was not independently retrieved.

Cross-Monitor Connections

The beneficial-ownership thread connects to broader corporate-transparency architecture questions that recur across jurisdictions assessed for enabler risk: a publicly searchable register with no independent verification function is structurally different from one with active verification, even where both pass a formal transparency test, and that distinction is the kind of structural-versus-episodic signal that carries weight beyond a single evaluation cycle. The crypto standing-context item connects to financial-innovation monitoring generally, in that a securities-law test narrowing around decentralized-exchange-traded tokens affects how enforcement theories are framed for digital-asset activity reaching Quebec counterparties, independent of any gambling-sector digital-asset question.

Outlook

What would most change this picture is a primary statement from the Registraire des entreprises or the Commission d'acces a l'information addressing the public-searchability and verification-gap characterization directly, since the current provincial-level claim rests on secondary commentary rather than a first-party source. On the federal plane, the FATF evaluation itself flagged continuing weaknesses in administrative monetary penalty practice and in standalone money-laundering prosecution, and movement on either of those fronts would be the next marker of whether Canada's improved follow-up status consolidates further.

11 Aug 2026 · fim-2026-08-05

Lead Signal

The Canadian anti-money-laundering architecture underwent its most significant reinforcement in years this cycle, driven by two Royal Assent events on March 26, 2026: amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act raising the administrative penalty ceiling for very serious violations from 500,000 dollars to 20,000,000 dollars, and enactment of a new Stablecoin Act imposing duties on stablecoin creators and issuers offering services to persons in Canada (fim-2026-W32-001; fim-2026-W32-002). The penalty increase, delivered through the Budget 2025 Implementation Act and the Strengthening Canada Immigration System and Borders Act, is a structural rather than incidental shift: a fortyfold increase in the ceiling for the most serious violation category signals an intent to make the FINTRAC administrative-penalty regime a credible deterrent rather than a cost of doing business, particularly for cross-sector money-services businesses. Running in parallel, the Canadian sanctions architecture continued an aggressive G7-aligned cadence, with Global Affairs Canada adding seven individuals and more than thirty entities under the Special Economic Measures (Russia) Regulations effective June 12, 2026, targeting energy, defense-industrial, disinformation, and shadow-fleet shipping actors (fim-2026-W32-003). Unusually, the same instrument repealed the procedural delisting-review obligations under subsections 8(3) and 8(4), a rare formal repeal of an accountability mechanism that Global Affairs Canada has framed as a procedural-fairness improvement (fim-2026-W32-004). Read together, Canada is simultaneously tightening the domestic AML penalty architecture and the sanctions-designation reach while loosening one procedural safeguard on the delisting side, an asymmetry worth tracking for legal and compliance functions alike.

Other Developments

A mutual evaluation clears a hurdle. The Financial Action Task Force adopted its mutual evaluation of Canada at the June 2026 Plenary, with provisional ratings reported as sufficient to avoid grey-listing pending the final report due in the third or fourth quarter of 2026 (fim-2026-W32-005). Residual supervisory scrutiny tied to prior large-bank enforcement history remains a live line of inquiry pending the full report.

Cartel-finance enforcement widens into casino-linked typologies. FinCEN issued a supplemental alert on fiscal fuel-theft and tax-evasion schemes associated with the Cartel Jalisco Nueva Generacion, documenting red-flag typologies that extend trade-based money-laundering enforcement attention toward casino-linked designations along the Mexico-United States border corridor (fim-2026-W32-006).

Cambodian exposure escalates on two fronts. The central bank governor publicly warned that Cambodia must avoid re-listing amid casino and scam-compound money-laundering exposure, while separately, secondary reporting indicates the United States Treasury sanctioned a Cambodian senator-linked casino and hospitality network in April 2026 over alleged scam-centre property ownership; no Tier-1 OFAC source was directly retrieved this cycle, so that designation is held at Assessed confidence pending primary corroboration (fim-2026-W32-007; fim-2026-W32-008).

A capacity gap surfaces in the unregulated online-gambling perimeter of Quebec. An industry coalition estimates approximately 2,000 unlicensed gambling websites currently serve players in Quebec, with a claimed tax-revenue leakage of more than 300 million dollars annually; this figure is sourced from an interested industry party contesting the Loto-Quebec monopoly and has not been independently quantified by FINTRAC or a provincial regulator, so it is held at Low confidence (fim-2026-W32-009).

Canada builds a purpose-built stablecoin-integrity regime. Beyond the FINTRAC registration requirement noted above, the Bank of Canada is expected to maintain a public registry of stablecoin issuers running parallel to FINTRAC enrolment, though the implementing regulations remain pending (fim-2026-W32-010).

Cross-Monitor Connections

The unregulated-gambling perimeter identified in Quebec this cycle sits at the intersection of this monitor enabler-jurisdiction lens and a gambling-regulatory monitor competitive-landscape tracking of the same coalition dispute; where a gambling monitor reads the 2,000-site estimate as a market-access argument, this monitor reads the same absence of a provincial licensing perimeter as a capacity deficit carrying money-laundering exposure implications, since unlicensed online gambling operates outside any AML and CTF reporting-entity obligation. The Cambodian casino-linked scam-compound economy is a standing connection to conflict-adjacent and forced-labor financial flows that a state-capture-focused monitor would read as enablement through inaction, given the central bank own public acknowledgment of grey-list risk sitting alongside continued casino-sector operation. The Mexican fuel-theft financing of Cartel Jalisco Nueva Generacion operations is a direct line to commodity-flow monitoring: the same fiscal fuel-theft infrastructure that the FinCEN alert describes as sustaining armed cartel operations is a smuggled-commodity flow that a resource and extractive-integrity lens would track from the supply side rather than the financial-typology side.

Outlook

Watch for the full publication of the Mutual Evaluation Report, expected in the third quarter of 2026, which will confirm whether the provisional ratings translate into a clean result or whether supervisory-effectiveness findings temper it (fim-reg-2026-060). On the stablecoin front, the coming-into-force regulations for FINTRAC registration and the public issuer registry of the Bank of Canada remain a multi-year horizon item; until those regulations publish, stablecoin issuers in Canada operate under enacted statutory duties without a fully built supervisory registration architecture (fim-reg-2027-010). Whether the unregulated online-gambling perimeter in Quebec narrows will depend on a provincial policy decision that remains, as of this cycle, at the pre-budget-submission stage rather than the legislative stage.

14 Jul 2026 · fim-2026-07-14

Lead Signal

The defining feature of this baseline cycle for Quebec and the federal Canadian anti-money-laundering architecture is not a single enforcement action but a structural gap that has stood, largely unaddressed, for more than a decade. A 2015 Supreme Court ruling declared the investigatory and reporting powers of FINTRAC constitutionally inoperative with respect to legal counsels, legal firms and Quebec notaries, removing an entire class of high-risk gatekeepers from anti-money-laundering and counter-terrorist-financing supervision in conveyancing, corporate formation, trust structuring and estate transfer. Assessed with high confidence, this carve-out is the clearest illustration this cycle of the architecture-over-incident principle: it is a durable feature of the Canadian civil-law and constitutional order, not an episodic lapse, and it will be re-tested when the Financial Action Task Force convenes its indicative Plenary discussion of the Canadian fifth-round effectiveness mutual evaluation.

Alongside the notary carve-out, a second lead signal concerns the crypto sector, where the direction of travel is more ambiguous. FINTRAC imposed its largest-ever penalty, close to 176 million Canadian dollars, on Xeltox Enterprises, operating as Cryptomus, for failing to file suspicious transaction reports on flows linked to child sexual abuse material, fraud, ransomware and sanctions evasion, and followed this with a wave of roughly thirty-five crypto money-service-business registration revocations. Yet on-chain analysis assessed with confidence that a no-KYC successor platform, Heleket, emerged within the same month, drawing the same high-risk user base across Nigeria, Russia and India. Together these two signals frame the cycle: a legal architecture that structurally exempts an entire professional class, and an enforcement architecture whose intensity is real but whose deterrent effect is being circumvented in near real time.

Other Developments

Sanctions coordination without convergence. Global Affairs Canada designated 100 Russian shadow-fleet vessels and drone-component manufacturers under the Special Economic Measures Act, announced jointly with Ukraine at a G7 Foreign Ministers meeting. This action sits within a Russian evasion architecture that uses flag-hopping tankers, opaque intermediary ownership and United Arab Emirates and Hong Kong-based trading hubs to access Western trade finance and insurance while circumventing the price cap. Canada functions here as a target and coalition jurisdiction rather than a primary enabler, but the Canadian regime remains legally distinct from the OFAC and OFSI architecture, with no automatic mutual recognition of designations and a narrower administrative capacity for licensing and wind-down mechanics, generating cross-border compliance friction for Quebec and Montreal institutions. The scale differential is notable: the nineteenth European Union sanctions package listed 557 shadow-fleet vessels and named Litasco Middle East DMCC as an enabler, against the narrower Canadian listing of 100 vessels. Procedurally, FINTRAC implements Financial Action Task Force list changes through ministerial guidance rather than direct statutory advisory, a mechanism divergence from FinCEN and OFSI that is assessed as procedural rather than substantive.

Registry fragmentation and the real estate channel. Montreal is named, alongside Vancouver and Toronto, as a concentration point for money laundering through property purchases, sustained by historically low suspicious-transaction-report filing rates in the real estate sector despite nominal coverage under the federal statute. This channel capacity persists against a beneficial-ownership picture that remains fragmented across federal-provincial lines: the federal registry, operational since January 2024, covers only federally incorporated entities, while the Quebec provincial registrar operates independently with inconsistent disclosure standards and no confirmed alignment commitment as of this baseline.

Provincial participation in federal enforcement. The Quebec Autorite des marches financiers, the provincial securities and insurance regulator, participated as a coalition partner alongside the Ontario Provincial Police and the British Columbia Securities Commission in Project Atlas and Operation Avalanche, blockchain-analytics-enabled operations that identified more than two thousand fraud-linked wallet addresses across fourteen countries and disrupted Ethereum-based scam networks tied to over seventy million dollars in combined losses.

Clean list status heading into re-evaluation. The February 2026 Financial Action Task Force Plenary added Kuwait and Papua New Guinea to increased monitoring while Iran, the Democratic Peoples Republic of Korea and Burma remain the only call-for-action jurisdictions; Canada appears on neither list. This clean standing will be tested directly when the Canadian fifth-round mutual evaluation effectiveness report reaches its indicative Plenary discussion window, itself constrained this cycle by a residual sourcing gap, since no direct Quebec-specific provincial regulatory primary source could be retrieved, leaving Quebec-specific findings substantiated through national-level Financial Action Task Force and Government of Canada documents.

Cross-Monitor Connections

The Russian shadow-fleet and drone-component procurement network touching the Canadian sanctions regime carries dual-use military-procurement and conflict-finance relevance that extends beyond core anti-money-laundering, counter-terrorist-financing and counter-proliferation-financing scope, and has been flagged to the state-capture monitor at medium cross-monitor scale. The same evasion architecture, structurally distinct from any primary Canadian enabler role, carries a secondary conflict-finance dimension: Canadian participation as a target and counter-party jurisdiction in sustaining Russian war-economy revenue despite coordinated G7 price-cap controls is a downstream signal rather than a direct extractive-industry or armed-conflict financing channel originating in Quebec or Canada. No direct Quebec-specific conflict-finance or extractive-industry finding arose this cycle; the connection is carried entirely through the sanctions-evasion architecture rather than a distinct commodity-flow or war-economy financing channel domestic to this jurisdiction.

Outlook

Three forward-looking items structure the near-term horizon. The Canadian fifth-round mutual evaluation effectiveness assessment, with an indicative onsite period reached in November 2025 and an indicative Plenary discussion window set for June 2026, both labelled subject to change by the Financial Action Task Force, will re-examine the notary carve-out and broader designated-non-financial-business-and-profession supervision weaknesses flagged since 2016. Federal-provincial beneficial-ownership registry interconnection, including Quebec, is assessed with possible confidence as a 2027 development contingent on provincial buy-in with no confirmed Quebec commitment identified at this baseline. Separately, newly adopted Financial Action Task Force guidance on offshore virtual-asset service providers, stablecoins and unhosted wallets is expected to inform FINTRAC recalibration of registration thresholds and travel-rule enforcement, with direct relevance to scrutiny of no-KYC successor platforms. As of this baseline, the Xeltox appeal remains pending and no confirmed regulatory response to Heleket has been identified, leaving the crypto-enforcement trajectory and the notary-carve-out question as the two structural threads most likely to define the next several cycles.

Domain intelligence (D1–D8)

D1 Sanctions

no_changeno_changestanding position

Sanctions Architecture and Evasion

The Canadian posture toward Russia sanctions this cycle is best read as that of a coordinating enforcement jurisdiction rather than a primary enabler or evasion hub. Global Affairs Canada added 100 shadow-fleet vessels and Russian drone-component manufacturers to the autonomous sanctions list under the Special Economic Measures Act, announced jointly with the Ukrainian foreign minister at a G7 Foreign Ministers meeting, and paralleling contemporaneous European Union and United Kingdom shadow-fleet listings. This is a designation action, and under a three-level sanctions-architecture analysis it must be read at three registers: the scheme itself, the enabling architecture that sustains it, and the strategic consequence. At the scheme level, the underlying evasion network relies on flag-hopping tankers and opaque intermediary ownership. At the architecture level, United Arab Emirates and Hong Kong-based intermediary structures provide the connective tissue that gives this scheme access to Western trade finance and insurance despite the coordinated price cap. At the strategic level, the persistence of this architecture despite coordinated Canadian, European Union and United Kingdom listings indicates that Russian war-economy revenue generation continues to find channels around, rather than through, the sanctioned financial system.

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Canada participation in this architecture is structurally that of a target and counter-party jurisdiction rather than a channel jurisdiction: the evasion network moves sanctioned commodities and dual-use goods through third-country trading hubs, and Canada, alongside its G7 and Price Cap Coalition partners, responds through designation rather than serving as a transit point. This distinction matters analytically, because it separates Canada from enabler jurisdictions whose legal frameworks or enforcement gaps actively facilitate evasion, and situates it instead within the coordinated sanctioning bloc. That said, coordination is not convergence. The Canadian regime under the Special Economic Measures Act remains legally independent from the OFAC and OFSI architecture, with distinct national listing criteria, no automatic mutual recognition of designated vessels or entities across jurisdictions, and a narrower administrative capacity for licensing and wind-down mechanics relative to its larger G7 partners. This divergence generates real compliance friction for Quebec and Montreal-based financial institutions transacting cross-border with United States and European Union counterparties, who must reconcile three semi-aligned but legally distinct listing regimes. The scale differential underscores the point: the nineteenth European Union sanctions package listed 557 shadow-fleet vessels and named Litasco Middle East DMCC as an enabler, a designation scope roughly five times the Canadian action of 100 vessels, suggesting Canada operates with narrower administrative reach even while sharing strategic objectives with its coalition partners.

A further procedural divergence concerns the mechanism by which Financial Action Task Force list changes are operationalised domestically. FINTRAC implements these changes through ministerial guidance rather than a direct statutory advisory mechanism comparable to FinCEN or OFSI practice. This is assessed as a procedural rather than substantive divergence, distinguishing a difference in implementation timing and mechanism from any deficiency in underlying capacity or intent. Canada remains, as of the February 2026 Financial Action Task Force Plenary, absent from both the increased-monitoring list and the call-for-action list, a clean standing that nonetheless awaits confirmation through the pending fifth-round mutual evaluation effectiveness assessment, whose indicative onsite period reached November 2025 and whose indicative Plenary discussion window is set for June 2026.

Outlook

The most consequential near-term marker for this domain is the Canadian fifth-round mutual evaluation effectiveness report, whose outcome will shape correspondent-banking risk perception for Quebec-linked institutions and re-test the technical-compliance gaps that FATF has flagged since 2016. Further Canadian Special Economic Measures Act listing rounds, continued G7 Price Cap Coalition coordination at the revised 47.6-dollar-per-barrel cap level, and the European Union twentieth sanctions package follow-through are the standing watch items most likely to test whether the current pattern of coordination without convergence narrows or widens over coming cycles.

Judgment: No CA-QC-specific sanctions-evasion nexus surfaced this cycle; sanctions designation remains federal. Uncertain
Cumulative analysis

Sanctions Architecture and Evasion — Cumulative Analysis

This baseline cycle establishes the Canadian sanctions-architecture profile for the Quebec and federal context. The durable finding is that Canada functions as a coordinating enforcement and target jurisdiction within the G7 and Price Cap Coalition framework rather than as a primary enabler of Russian sanctions evasion. This was established through the November 2025 Special Economic Measures Act designation of 100 Russian shadow-fleet vessels and drone-component manufacturers, announced jointly with Ukraine at a G7 Foreign Ministers meeting and paralleling contemporaneous European Union and United Kingdom shadow-fleet listings.

Reading this designation through a three-level analysis situates it within a broader evasion architecture: flag-hopping tankers and opaque intermediary ownership structures based in the United Arab Emirates and Hong Kong provide access to Western trade finance and insurance despite the coordinated price cap, sustaining Russian war-economy revenue at the strategic level even as individual designations accumulate. Canada role throughout is that of a target and counter-party jurisdiction, not a channel jurisdiction, which distinguishes this file analytically from enabler-jurisdiction findings elsewhere in the Canadian profile.

The standing structural feature to track across cycles is coordination without convergence. The Canadian regime under the Special Economic Measures Act is legally independent from the OFAC and OFSI architecture, using distinct national listing criteria with no automatic mutual recognition of designations and comparatively narrower administrative capacity for licensing and wind-down mechanics. This generates persistent cross-border compliance friction for Quebec and Montreal-based institutions reconciling three semi-aligned regimes. The scale differential observed this cycle, a 100-vessel Canadian listing against a 557-vessel European Union listing under its nineteenth sanctions package that also named Litasco Middle East DMCC as an enabler, is a useful baseline metric for tracking whether Canadian listing scope narrows the gap with its larger partners in future cycles.

A second standing feature is the procedural, rather than substantive, divergence in how Financial Action Task Force list changes are domestically operationalised: FINTRAC relies on ministerial guidance rather than a direct statutory advisory mechanism comparable to FinCEN or OFSI. This distinguishes capacity and mechanism choice from any substantive non-compliance, and should be tracked separately from the clean list standing Canada holds as of the February 2026 Plenary, where it appears on neither the increased-monitoring nor the call-for-action list.

The pending fifth-round mutual evaluation effectiveness assessment is the single event most likely to reframe this domain profile in the near term, with its indicative onsite period reached in November 2025 and its indicative Plenary discussion window set for June 2026, both labelled subject to change by FATF. Future cycles should track further Special Economic Measures Act listing rounds, the pace of European Union twentieth sanctions package follow-through, and whether the Canadian administrative and licensing gap relative to OFAC and OFSI narrows or persists as a structural feature of the G7 coordination architecture.

domain_sub_briefs · D1 · Cumulative analysis
Periodic updates (1)
11 Aug 2026 · fim-2026-08-05

Sanctions

The Canadian sanctions architecture continued an aggressive, G7-aligned expansion cadence through this cycle, with Global Affairs Canada adding seven individuals and more than thirty entities under the Special Economic Measures (Russia) Regulations effective June 12, 2026 (fim-2026-W32-003). The designations target actors across the energy sector, the defense-industrial base, disinformation networks, and shadow-fleet shipping operations used to circumvent the Russian oil price cap, consistent with the pattern of Schedule 1 and Schedule 1.1 expansions Canada has pursued through February, May, and June 2026. The scale and sectoral breadth of the addition is itself the signal: shadow-fleet shipping designations extend the sanctions reach of Canada into the maritime-insurance and vessel-registration ecosystem that has become a primary evasion vector for Russian crude exports since the price cap was introduced.

More unusual, and arguably more consequential from an architecture perspective, is the same instrument repeal of subsections 8(3) and 8(4), which had governed Ministerial delisting-review obligations (fim-2026-W32-004). Formal repeals of procedural accountability mechanisms are rare events in sanctions administration, and this one runs counter to the general international trend toward strengthening delisting due-process protections in response to legal challenges to autonomous sanctions regimes elsewhere. Global Affairs Canada has publicly framed the repeal as a procedural-fairness and administrative-efficiency improvement, but the practical effect is to reduce the formal review obligations owed to a designated party seeking delisting, at the same moment the designation list is expanding. For institutions conducting sanctions screening against Canadian autonomous lists, the near-term operational implication is straightforward: the designated-party universe is growing, while the procedural pathway for a designated party to contest or exit that status has narrowed.

Sanctions-adjacent secondary reporting elsewhere this cycle reinforces the broader enforcement direction: a Cambodian senator-linked casino and hospitality network was reported sanctioned by the United States Treasury in April 2026 over alleged scam-centre property ownership, though this designation rests on secondary NGO and trade-press reporting rather than a directly retrieved Tier-1 OFAC source this cycle, and is held at Assessed rather than High confidence pending primary corroboration (fim-2026-W32-008).

Outlook

The near-term sanctions horizon for Canada tracks closely with the broader G7 cadence; no material autonomous-listing divergence from EU or UK positioning surfaced this cycle, suggesting continued coordinated designation activity rather than an independent Canadian sanctions posture. The delisting-review repeal is worth monitoring for whether it draws legal challenge domestically, given the due-process sensitivities that have accompanied similar procedural questions in allied sanctions regimes.

D2 Beneficial Ownership

stableactive

Beneficial Ownership and Corporate Transparency

Quebec's beneficial-ownership regime drew specific external validation this cycle through Canada's FATF Mutual Evaluation Report, which cites the Registraire des entreprises (REQ) public register as a corporate-transparency advance. The REQ regime requires ultimate-beneficiary disclosure as of 31 March 2023 under the Act respecting the legal publicity of enterprises, as amended by Bill 78, and has offered public name-based search since 31 July 2024. This gives Quebec one of the more publicly accessible beneficial-ownership search facilities among Canadian jurisdictions, predating the federal Canada Business Corporations Act significant-control-person framework in practical searchability terms. The finding is treated as probable: it derives from secondary reporting (AML Intelligence, ACAMS) describing the content of the FATF Mutual Evaluation Report rather than from the report itself, which was not directly retrieved this cycle. The underlying gap is recorded rather than absorbed into an unqualified assertion, consistent with the corroboration standard applied where a Tier 2 source reports on a Tier 1 instrument not independently verified.

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Standing architecture: globally, the EU AML Package sets a structural direction that is distinct from, and not directly applicable to, Quebec's regime. The package comprises three separate instruments -- the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive requiring Member State transposition, and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority -- and is reshaping EU-level supervision from a purely national model toward a hybrid regime combining AMLA direct supervision of selected cross-border obliged entities with continued national-authority oversight of the remainder. This is durable structural backdrop rather than a finding about Quebec; no interpreter horizon anchors on the EU AML Package applied to this jurisdiction this cycle, and the Quebec-specific signal is better read against its own REQ/CBCA architecture than against the EU's supervisory transition.

The practical significance of the REQ citation lies less in any single disclosure obligation than in its evidentiary role: an international standard-setter has now identified a specific sub-national Canadian beneficial-ownership mechanism as functioning well, inside a national evaluation that was otherwise critical of Canada's broader AML posture, particularly around professional money-laundering gatekeepers. That asymmetry -- a federally mixed picture alongside a provincially positive citation -- is itself an analytically relevant structural observation about where transparency infrastructure in Canada is concentrated.

Outlook

The REQ finding is likely to remain probable-tier until the FATF Mutual Evaluation Report text is directly retrieved and cross-checked against the secondary reporting that currently carries it. No regulatory_horizon anchors were supplied this cycle indicating a forthcoming amendment to the REQ regime or to Bill 78's disclosure provisions, so no forward-looking structural change is flagged. The register's public searchability feature is expected to continue functioning as a reference point in comparative Canadian beneficial-ownership assessments absent a contrary development.

Judgment: Quebec's REQ ultimate-beneficiary regime runs a 30-day update clock under LPLE art. 41, distinct from the federal CBCA ISC regime's 15-day clock; a standing structural variance, documented at JID level for the first time this cycle. Probable
Cumulative analysis

Beneficial Ownership and Corporate Transparency — Cumulative Analysis

Across this baseline, the Quebec and federal Canadian beneficial-ownership picture is defined by three interlocking domestic structural features rather than by any European regulatory development. The first and most consequential is the constitutional exclusion of legal counsels, legal firms and Quebec notaries from FINTRAC investigatory and reporting supervision, following a 2015 Supreme Court ruling that declared such powers inoperative in their respect. This decade-plus unresolved gatekeeper gap removes an entire high-risk professional class from anti-money-laundering reach in conveyancing, corporate formation, trust structuring and estate transfer, and stands as the clearest illustration in the Canadian file of the architecture-over-incident principle: a structural blind spot rather than an episodic enforcement lapse.

The second domestic structural feature is the real estate and casino laundering nexus, with Montreal named alongside Vancouver and Toronto as a concentration point for layering proceeds into property purchases, sustained across cycles by historically low suspicious-transaction-report filing rates in the real estate sector. The third is registry fragmentation: the federal Corporations Canada registry, operational since January 2024, provides beneficial-ownership coverage only for federally incorporated entities, while the Quebec Registraire des entreprises continues to operate independently, with inconsistent disclosure standards and no confirmed alignment commitment identified through this baseline. These three features interact: gatekeeper opacity, channel capacity in real estate, and registry fragmentation together sustain a domestic architecture through which beneficial ownership can be obscured using lawful means, independent of any cross-border facilitation.

The European Union AML Package remains the standing global structural backdrop against which beneficial-ownership regimes elsewhere are increasingly measured, and is tracked here for comparative context even though it carries no direct application to Canada. The package comprises three distinct instruments: the directly applicable AML Regulation, or AMLR, under Regulation (EU) 2024/1624; the sixth AML Directive, or 6AMLD, transposed individually by each member state; and the AMLA Regulation, under Regulation (EU) 2024/1620, establishing the Anti-Money Laundering Authority with a direct and indirect supervision perimeter that shifts European Union oversight from a purely national model toward a hybrid EU-level regime. Canada and Quebec sit entirely outside this perimeter, with exposure limited to indirect channels such as any future equivalence determination or high-risk third-country classification; none has been identified affecting Canada as of this baseline.

The domain trajectory going forward hinges on two linked developments. The pending Canadian fifth-round mutual evaluation effectiveness assessment, with its indicative Plenary discussion window set for June 2026, will directly re-test the notary carve-out and the broader designated-non-financial-business-and-profession supervision weaknesses that FATF has flagged since 2016, and its outcome is likely to shape correspondent-banking risk perception of Quebec-linked institutions. Separately, federal-provincial beneficial-ownership registry interconnection, assessed with possible confidence as a 2027 horizon item, remains contingent on Quebec buy-in that has not yet been confirmed. Future cycles should track any Quebec legislative movement toward federal registry alignment, updated real estate suspicious-transaction-report filing statistics, and whether the mutual evaluation outcome accelerates pressure on the notary carve-out that has persisted, materially unresolved, for more than a decade.

domain_sub_briefs · D2 · Cumulative analysis
Standing baseline position

FATF MER (reported ~Sept 2026) cites Quebec's REQ public beneficial-ownership register (ultimate-beneficiary disclosure since 31 Mar 2023; public search since 31 Jul 2024) as part of Canada's corporate-transparency progress.

Quebec's REQ ultimate-beneficiary regime runs a 30-day update clock under LPLE art. 41, distinct from the federal CBCA ISC regime's 15-day clock.

Periodic updates (4)
25 Oct 2026 · fim-2026-10-25

Beneficial Ownership and Corporate Transparency

Quebec's beneficial-ownership regime drew specific external validation through Canada's FATF Mutual Evaluation Report, which cites the Registraire des entreprises (REQ) public register as a corporate-transparency advance. The REQ regime requires ultimate-beneficiary disclosure as of 31 March 2023 under the Act respecting the legal publicity of enterprises, as amended by Bill 78, and has offered public name-based search since 31 July 2024. This gives Quebec one of the more publicly accessible beneficial-ownership search facilities among Canadian jurisdictions, predating the federal Canada Business Corporations Act significant-control-person framework in practical searchability terms. The finding is treated as probable: it derives from secondary reporting (AML Intelligence, ACAMS) describing the content of the FATF Mutual Evaluation Report rather than from the report itself, which was not directly retrieved. The underlying gap is recorded rather than absorbed into an unqualified assertion, consistent with the corroboration standard applied where a Tier 2 source reports on a Tier 1 instrument not independently verified.

Standing architecture: globally, the EU AML Package sets a structural direction that is distinct from, and not directly applicable to, Quebec's regime. The package comprises three separate instruments -- the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive requiring Member State transposition, and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority -- and is reshaping EU-level supervision from a purely national model toward a hybrid regime combining AMLA direct supervision of selected cross-border obliged entities with continued national-authority oversight of the remainder. This is durable structural backdrop rather than a finding about Quebec; no interpreter horizon anchors on the EU AML Package applied to this jurisdiction, and the Quebec-specific signal is better read against its own REQ/CBCA architecture than against the EU's supervisory transition.

The practical significance of the REQ citation lies less in any single disclosure obligation than in its evidentiary role: an international standard-setter has now identified a specific sub-national Canadian beneficial-ownership mechanism as functioning well, inside a national evaluation that was otherwise critical of Canada's broader AML posture, particularly around professional money-laundering gatekeepers. That asymmetry -- a federally mixed picture alongside a provincially positive citation -- is itself an analytically relevant structural observation about where transparency infrastructure in Canada is concentrated.

Outlook

The REQ finding is likely to remain until the FATF Mutual Evaluation Report text is directly retrieved and cross-checked against the secondary reporting that currently carries it. No regulatory horizon anchors were supplied indicating a forthcoming amendment to the REQ regime or to Bill 78's disclosure provisions, so no forward-looking structural change is flagged. The register's public searchability feature is expected to continue functioning as a reference point in comparative Canadian beneficial-ownership assessments absent a contrary development.

11 Oct 2026 · fim-2026-10-11

Beneficial Ownership

Quebec's beneficial-ownership picture this cycle is read through a federal finding that inherits down rather than through a standalone provincial development. The Financial Action Task Force and the Asia/Pacific Group adopted Canada's 2026 Mutual Evaluation Report, crediting beneficial-ownership transparency progress and moving Canada from enhanced to regular follow-up without a grey-listing. That finding is tier-one confirmed and sits at the federal layer; no CA-QC-specific finding beyond the REQ register characterization reached the same evidentiary bar this cycle.

Standing against that federal backdrop, Quebec's Registraire des entreprises ultimate-beneficiary register, amended under Bill 78 with effect from 31 March 2023, is cited by commentary as the kind of province-level architecture that contributed to the evaluators' overall picture. The register is described as freely and publicly searchable, a broader public-access posture than the federal Canada Business Corporations Act register, which notably does not offer equivalent open public search. That breadth of access, however, sits alongside two persistent limitations: the register retains a twenty-five percent control threshold for identifying a beneficial owner, and there is no independent verification of filer-submitted data. This composite characterization rests on a single tier-three secondary source, a law firm's published commentary, rather than a primary statement from the Registraire itself or from the Commission d'acces a l'information, which is why the finding is recorded at a probable rather than confirmed tier even though the underlying federal FATF evaluation is itself confirmed at tier one.

The durable structural fact behind beneficial-ownership regulation at the European level, for comparison, is that the EU AML Package comprises three distinct instruments: the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive transposed per Member State, and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority, which shifts supervision from purely national authorities toward a hybrid EU-level regime. Canada and Quebec sit outside that architecture entirely; no AMLA horizon anchor applies to this jurisdiction, and the comparison is offered only as a structural contrast against which Quebec's own register characteristics, public access without independent verification, can be read, rather than as a suggestion that Quebec operates under or alongside any EU instrument.

What would most change this provincial-level picture is a primary statement from the Registraire or the Commission d'acces a l'information addressing the public-searchability and verification-gap characterization directly. Absent that, the finding remains anchored in secondary commentary, a limitation this brief states plainly rather than treating the register comparison as settled fact beyond what the federal evaluation itself confirmed.

Outlook

The federal FATF evaluation's weaknesses, continuing gaps in administrative monetary penalty practice and in standalone money-laundering prosecution, are the clearest markers to watch for whether Canada's improved follow-up status consolidates. At the provincial level, a first-party statement from Quebec's corporate registry on verification practice would resolve the open question the current commentary-based characterization leaves standing.

11 Aug 2026 · fim-2026-08-05

Beneficial Ownership

The beneficial-ownership and corporate-transparency architecture of Canada itself is not the site of this cycle most direct movement; the material development in the neighbouring compliance-obligation space is the Budget 2025 Implementation Act amendment to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, which raises the administrative penalty ceiling for very serious violations from 500,000 dollars to 20,000,000 dollars (fim-2026-W32-001). While framed principally as a sanctions-and-AML enforcement-architecture change, a penalty regime of this scale bears on the beneficial-ownership compliance stack, since failure to obtain, verify, or report accurate beneficial-ownership information from customers is itself charged under the same violation-severity framework now carrying materially higher exposure.

Standing behind any Canada-specific beneficial-ownership assessment is the structural backdrop against which the transparency architecture of the European Union is now organised. The EU AML Package comprises three distinct instruments: the directly applicable AML Regulation (AMLR, Regulation (EU) 2024/1624), the sixth AML Directive (6AMLD) requiring Member State transposition, and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority. Together these shift beneficial-ownership and broader AML supervision from a purely national-authority model toward a hybrid regime in which AMLA exercises direct supervision over a defined set of cross-border obliged entities and indirect supervisory oversight over the remainder. This architecture is not the primary subject for Canada, which sits outside the EU framework entirely, but it is the durable global reference point against which any national beneficial-ownership regime, including that of Canada, is increasingly benchmarked by FATF-aligned peer review. No AMLR, 6AMLD, or AMLA-specific development materially touching Canada surfaced this cycle; this paragraph is carried as standing structural context rather than a new-development claim.

Outlook

The beneficial-ownership perimeter of Canada will be a relevant line item in the Mutual Evaluation Report due for full publication in the third quarter of 2026; corporate-registry discrepancy-reporting obligations that came into effect in prior cycles continue bedding into supervisory practice, though no new development in that specific area was located this cycle.

14 Jul 2026 · fim-2026-07-14

Beneficial Ownership and Corporate Transparency

The developments most directly relevant to Quebec and the federal Canadian beneficial-ownership perimeter this cycle are domestic rather than European. The single most structurally significant finding is a 2015 Supreme Court ruling that declared FINTRAC investigatory and reporting powers over legal counsels, legal firms and Quebec notaries constitutionally inoperative. This is not a recent development but a persistent, decade-plus unresolved gap: an entire class of high-risk gatekeepers involved in conveyancing, corporate formation, trust structuring and estate transfer remains outside FINTRAC supervisory and reporting reach. Read under the architecture-over-incident principle, this constitutional carve-out is analytically weightier than any single enforcement action, because it defines the durable shape of what beneficial-ownership opacity can be built through in Quebec, using entirely lawful and constitutionally protected professional channels.

Compounding this gatekeeper gap is a second domestic finding: real estate and, to a lesser extent, casino transactions are identified as principal channels for layering proceeds into Canadian property markets, with Montreal named alongside Vancouver and Toronto, sustained by historically low suspicious-transaction-report filing rates in the real estate sector despite nominal coverage under the federal statute. A third domestic finding concerns registry architecture itself: the federal Corporations Canada registry has accepted beneficial-ownership filings since January 2024, but it covers only federally incorporated entities, while the Quebec Registraire des entreprises operates independently, with inconsistent disclosure standards and no confirmed commitment to align with the federal standard identified as of this baseline. Together, the notary carve-out, the real estate channel and the registry fragmentation form a coherent Quebec-specific beneficial-ownership risk architecture that exists independently of any European regulatory development.

Globally, the European Union AML Package sets the structural direction that most other jurisdictions are eventually assessed against, and it is useful as backdrop context even though Canada sits entirely outside its direct perimeter. That package is properly understood as three distinct instruments rather than a single reform: the AML Regulation, or AMLR, under Regulation (EU) 2024/1624, which is directly applicable across European Union member states without need for domestic transposition; the sixth AML Directive, or 6AMLD, which each member state transposes individually into national law; and the AMLA Regulation, under Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority itself. The practical effect of this three-instrument architecture is a shift in the European Union supervisory perimeter from purely national competent authorities toward a hybrid regime, in which the Authority takes on direct supervision of a defined set of higher-risk cross-border obliged entities while indirect supervision of the remainder continues to run through national authorities operating under the directly applicable Regulation and the transposed Directive. For Canada and Quebec, this hybrid European architecture carries no direct transposition or supervisory obligation; exposure is indirect at most, running through any future European Union equivalence determination or high-risk third-country classification that could affect correspondent-banking relationships. No such equivalence action specific to Canada has been identified in this baseline cycle.

Outlook

The most consequential near-term marker in this domain is the interaction between the pending Canadian fifth-round mutual evaluation, which will directly re-test the notary carve-out and broader designated-non-financial-business-and-profession supervision weaknesses first flagged in 2016, and the separate question of federal-provincial beneficial-ownership registry interconnection. The latter is assessed with possible confidence as a 2027 development, contingent on provincial buy-in that includes no confirmed Quebec commitment as of this baseline. Watch items include any Quebec legislative move to align Registraire des entreprises disclosure with the federal standard, updated provincial corporate-secrecy scorecards, and whether the pending mutual evaluation outcome increases correspondent-banking scrutiny of the unresolved gatekeeper gap.

D3 Enabler Jurisdictions

stableactivestanding position

Enabler Jurisdictions and Professional Facilitators

Quebec presents a distinctive enabler-jurisdiction profile within the Canadian federal system, defined by a dual civil-law and constitutional architecture that operates alongside, rather than fully within, the federal PCMLTFA and FINTRAC regime. The central structural feature is the same notary and legal-counsel carve-out already identified as a beneficial-ownership gap: the 2015 Supreme Court ruling that excluded legal counsels, legal firms and Quebec notaries from FINTRAC supervision leaves conveyancing, incorporation and trust work largely outside FINTRAC reach. Viewed through the enabler-jurisdiction filter, this is best assessed as an unresolved question of constitutional capacity rather than deliberate policy choice, since the exclusion derives from a judicial ruling on the scope of federal power rather than from any legislative decision to shield these professions. This distinction matters analytically: it separates Quebec from enabler jurisdictions whose permissiveness reflects deliberate regulatory choice, and situates it instead in a narrower category where a genuine capacity constraint, rooted in constitutional law, has not yet been legislatively or judicially resolved.

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A second enabler-jurisdiction feature is the persistence of the Montreal real estate and casino laundering nexus, again reflecting a supervisory gap in designated-non-financial-business-and-profession coverage that has been flagged since at least the 2016 Financial Action Task Force mutual evaluation without apparent resolution in filing behaviour. The third feature is institutional: the Quebec Autorite des marches financiers operates as a distinct provincial securities and insurance regulator alongside the federal FINTRAC and the Office of the Superintendent of Financial Institutions, creating a dual provincial-federal supervisory architecture. This duality cuts both ways. On one hand, it creates a coordination surface, demonstrated this cycle through the AMF role as a coalition partner in Project Atlas and Operation Avalanche, national crypto-fraud disruption operations. On the other hand, dual provincial and federal architecture creates potential supervisory-perimeter gaps of the kind already visible in the beneficial-ownership registry fragmentation between the federal and Quebec systems.

A notable finding this cycle is a residual sourcing-floor gap rather than a substantive one: no direct Autorite des marches financiers Quebec or Registraire des entreprises du Quebec primary publication could be retrieved within the research window, meaning Quebec-specific findings in this baseline are substantiated through national-level Financial Action Task Force and Government of Canada documents rather than direct provincial primary sourcing. This is flagged transparently as a gap for future-cycle closure rather than treated as an indication of provincial opacity in itself.

The broader Canadian enabler-jurisdiction standing is shaped by the approaching Financial Action Task Force fifth-round mutual evaluation, whose effectiveness-based methodology is expected to re-test exactly these unresolved technical-compliance gaps: the notary carve-out and designated-non-financial-business-and-profession supervision weaknesses first identified in 2016. The indicative onsite period reached November 2025 and the indicative Plenary discussion window is set for June 2026, both labelled subject to change by the Financial Action Task Force, and the outcome will shape correspondent-banking risk perception specifically for Quebec-linked institutions given the concentration of these gaps in the province.

Outlook

Publication and adoption of the Canadian fifth-round mutual evaluation outcome is the defining watch item for this domain, with a subsequent report publication lag comparable to that observed for other assessed jurisdictions such as Austria, Italy and Singapore. A secondary watch item is direct retrieval of an Autorite des marches financiers Quebec or Registraire des entreprises du Quebec primary publication, which would close the residual sourcing gap identified this cycle and permit a more granular, Quebec-sourced enabler-jurisdiction assessment in future cycles.

Judgment: Quebec remains the only Canadian province layering a provincial MSB licence on top of mandatory federal FINTRAC registration, now extended to cryptoasset ATMs since 1 April 2025. Probable
Cumulative analysis

Enabler Jurisdictions and Professional Facilitators — Cumulative Analysis

The cumulative enabler-jurisdiction profile for Quebec, established across this baseline, centres on the interaction of a genuine constitutional capacity constraint with a dual provincial-federal supervisory architecture. The core structural feature is the 2015 Supreme Court ruling excluding legal counsels, legal firms and Quebec notaries from FINTRAC investigatory and reporting supervision, leaving conveyancing, incorporation and trust work outside federal AML and CFT reach. Assessed under the enabler-jurisdiction filter, this is best read as an unresolved capacity question rooted in constitutional law rather than a deliberate policy choice to shield these professions, which distinguishes Quebec from enabler jurisdictions whose permissiveness reflects an active regulatory decision.

A second recurring feature is the Montreal real estate and casino laundering nexus, a designated-non-financial-business-and-profession supervisory gap flagged since the 2016 Financial Action Task Force mutual evaluation and apparently unresolved in filing behaviour through this baseline. A third structural feature is institutional duality: the Quebec Autorite des marches financiers operates as a distinct provincial regulator alongside the federal FINTRAC and the Office of the Superintendent of Financial Institutions. This duality creates both a coordination surface, evidenced by AMF participation as a coalition partner in Project Atlas and Operation Avalanche, and a potential supervisory-perimeter gap, mirrored in the beneficial-ownership registry fragmentation between the federal and Quebec systems documented elsewhere in this baseline.

A transparent methodological finding threading through this cycle is a residual sourcing-floor gap: no direct Autorite des marches financiers Quebec or Registraire des entreprises du Quebec primary publication could be retrieved, meaning Quebec-specific findings rely on national-level Financial Action Task Force and Government of Canada sourcing. This is recorded as an evidentiary limitation to be closed in future cycles, not as a substantive finding of provincial opacity.

The domain trajectory is best characterised as uncertain rather than stable or improving, precisely because the approaching Financial Action Task Force fifth-round mutual evaluation, using an effectiveness-based rather than purely technical-compliance methodology, is expected to re-test the same gaps that have persisted since the 2016 evaluation: the notary carve-out and designated-non-financial-business-and-profession supervision weaknesses. The indicative Plenary discussion window set for June 2026 will be the single most consequential near-term event for this domain, and its outcome is likely to shape correspondent-banking risk perception of Quebec-linked institutions specifically, given the concentration of these unresolved gaps in the province relative to the rest of the federal system. Future cycles should track the publication and adoption of the mutual evaluation outcome, any subsequent report publication lag, and whether direct Quebec-sourced primary publications become available to close the sourcing gap identified in this baseline.

domain_sub_briefs · D3 · Cumulative analysis
Periodic updates (1)
11 Aug 2026 · fim-2026-08-05

Enabler Jurisdictions

This cycle enabler-jurisdiction signal is triangulated across three distinct geographies, each illustrating a different enablement mechanism. In Cambodia, the central bank governor issued a public warning that the country must avoid re-listing on the FATF grey list amid continuing casino and scam-compound money-laundering exposure (fim-2026-W32-007), a rare instance of a jurisdiction own senior official acknowledging enablement risk in public rather than having it surfaced solely by external monitors. Separately, secondary reporting indicates the United States Treasury sanctioned a Cambodian senator-linked casino and hospitality network in April 2026 over alleged ownership of scam-centre properties (fim-2026-W32-008); the absence of a directly retrieved Tier-1 OFAC source for this designation caps it at Assessed confidence, but the pairing of an official grey-list warning with a senator-linked casino sanctions action is a structurally significant combination regardless of the confidence tier on the second data point.

In Mexico, the FinCEN supplemental alert on Cartel Jalisco Nueva Generacion fiscal fuel-theft and tax-evasion schemes documents red-flag typologies that extend trade-based money-laundering enforcement attention toward casino-linked designations along the Mexico-United States border corridor (fim-2026-W32-006), reinforcing the standing profile of Mexico as an enforcement-active but structurally challenged enabler environment.

Closer to home, the unregulated online-gambling perimeter of Quebec surfaced this cycle as a domestic enabler-architecture question. An industry coalition estimates approximately 2,000 unlicensed gambling websites currently serve players in Quebec, absent any provincial licensing or AML and CTF reporting-entity perimeter, with a claimed annual tax-revenue leakage exceeding 300 million dollars (fim-2026-W32-009). This claim originates from an interested industry party pressing for a licensed, Ontario-style market structure, and it has not been independently quantified by FINTRAC or a Quebec regulator; it is held at Low confidence for that reason. Nonetheless, the underlying structural point, that players in Quebec can access a large volume of unlicensed gambling websites entirely outside any provincial or federal AML and CTF reporting obligation, stands as a capacity deficit worth tracking independent of the tax-revenue figure precision.

Outlook

Cambodia trajectory bears watching ahead of any FATF follow-up review, given that a domestic official has now publicly flagged re-listing risk. The Mexican fuel-theft enforcement line is likely to generate further FinCEN guidance as the typology matures. The Quebec enabler gap will resolve only if the provincial Ministry of Finance responds substantively to the pending pre-budget brief; absent independent regulatory quantification, the 300-million figure should be treated as an advocacy estimate rather than a supervisory finding.

D4 Conflict Finance

no_changeno_changestanding position

Conflict Finance and Extractive-Industry Integrity

This baseline cycle identifies no direct Quebec-specific or Canadian conflict-finance or extractive-industry finding. Signal in this domain is limited and indirect, arriving only through the Russian shadow-fleet and drone-procurement sanctions-evasion architecture already assessed under the sanctions domain. That architecture, which uses flag-hopping tankers, opaque intermediary ownership and third-country trading hubs to sustain Russian war-economy revenue despite the coordinated G7 price cap, carries a secondary conflict-finance dimension because the underlying commodity flows and dual-use goods movement help fund an active armed conflict. Canada participation in this architecture, however, is structurally that of a target and coalition-member jurisdiction responding through Special Economic Measures Act designation, not a channel jurisdiction through which conflict-finance flows are laundered or facilitated domestically. This distinction is important: the relevance to this domain is real but derivative, arising from Canada position within the broader sanctions and coalition-coordination file rather than from any distinct extractive-industry, artisanal-mining, or armed-group financing channel located in Quebec or Canada itself.

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Honesty over coverage governs this entry: rather than construct an extended domestic conflict-finance or extractive-industry narrative where the evidentiary base does not support one, this cycle records the domain as watch status with a secondary, cross-referenced signal only. This secondary signal has also been flagged to the state-capture monitor given its dual-use military-procurement relevance beyond core financial-integrity scope.

Outlook

The principal watch item for this domain is whether future cycles surface any direct Quebec-specific or Canadian extractive-industry, artisanal-mining, or conflict-adjacent commodity-finance channel. Absent such a finding, this domain will continue to be populated only through its cross-reference to the Russian shadow-fleet sanctions-evasion architecture tracked under the sanctions domain, and any material change in that architecture, including further Special Economic Measures Act listing rounds or a shift in Canada role from target to a more proximate channel jurisdiction, would be the trigger for reassessing this domain status.

Judgment: No CA-QC-specific conflict-finance nexus surfaced this cycle. Uncertain
Periodic updates (1)
11 Aug 2026 · fim-2026-08-05

Conflict Finance

This cycle conflict-finance signal is narrow but significant: FinCEN issued a supplemental alert on fiscal fuel-theft and tax-evasion schemes associated with the Cartel Jalisco Nueva Generacion, documenting the methodologies and red-flag typologies through which the cartel extracts illicit revenue from stolen and smuggled fuel (fim-2026-W32-006). The alert frames this fiscal fuel theft as a major non-drug revenue stream sustaining the armed operations of the cartel along the Mexico-United States border, a reminder that cartel financing extends well beyond narcotics proceeds into extractive and commodity-adjacent theft. No additional conflict-finance or extractive-industry-integrity development was identified this cycle beyond this single alert; coverage of this domain remains thin relative to the AML and sanctions pillars, consistent with the general three-pillar imbalance that under-weights CTF and CPF-adjacent findings relative to AML enforcement volume.

Outlook

Further FinCEN guidance on cartel fuel-theft financing is plausible as the typology receives continued regulatory attention; watch for whether any Canadian financial institution exposure to correspondent or trade-finance relationships touching this typology surfaces in a future cycle.

D5 Crypto / Digital Assets / Financial Innovation

stableactivestanding position

Crypto, Digital Assets, and Financial Innovation

The developments most directly relevant to this domain are domestic Canadian regulatory and enforcement actions rather than global standard-setting. FINTRAC imposed a record penalty of close to 176 million Canadian dollars on Xeltox Enterprises, operating as Cryptomus, for violations of the Proceeds of Crime, Money Laundering and Terrorist Financing Act, including failure to file suspicious transaction reports on transactions linked to child sexual abuse material, fraud, ransomware and sanctions evasion. The firm is appealing, and the appeal outcome is pending as of this baseline, with potential precedent-setting implications for penalty quantum in future suspicious-transaction-report-failure cases. This penalty sits within a broader supervisory drive: FINTRAC also revoked approximately thirty-five crypto money-service-business registrations between 2025 and 2026, following investigative reporting on unregistered Toronto-area crypto shops, though observers note an enforcement lag since some registrations had already expired since 2024, moderating confidence in the deterrent effectiveness of the revocation wave taken alone.

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The most analytically significant finding in this domain, however, is not the enforcement intensity itself but what followed it. On-chain analysis assessed with confidence that Heleket, an apparent no-KYC successor platform, emerged within the same month as the Cryptomus penalty, drawing the same high-risk user base across Nigeria, Russia and India, with illicit-flow share shifting structurally to the unregulated successor. This is a textbook enforcement-circumvention pattern: national enforcement against a foreign-registered money-service business is structurally circumvented by standing up an ostensibly separate no-KYC entity serving the same customer base. No confirmed FINTRAC or international regulatory action against Heleket has been identified as of this baseline, and the platform continues serving an overlapping high-risk user base.

Set against this enforcement-and-circumvention pattern is a genuine active-defence success: Project Atlas and Operation Avalanche, coordinated operations involving the Ontario Provincial Police, the British Columbia Securities Commission and the Quebec Autorite des marches financiers, supported by blockchain analytics, identified over two thousand fraud-linked wallet addresses across fourteen countries and disrupted Ethereum-based scam networks linked to more than seventy million dollars in combined scam losses. The participation of a provincial securities regulator alongside federal and other provincial bodies in a blockchain-analytics-enabled operation is itself a notable D5 and D6 cross-domain signal of tooling maturity.

Globally, the Financial Action Task Force adopted offshore virtual-asset service provider, stablecoin and unhosted-wallet guidance at its February 2026 Plenary. This is properly read as contextual backdrop rather than the domestic lead story: its relevance to Canada lies in its expected influence on FINTRAC recalibration of registration thresholds and travel-rule enforcement for platforms serving Canadian users, a recalibration with direct bearing on exactly the kind of no-KYC successor-platform pattern illustrated by Heleket.

Outlook

The crypto-enforcement trajectory in this domain is assessed as improving in intensity but incompletely resolved in effect. Three watch items dominate: the outcome of the Xeltox appeal, any regulatory response to Heleket, and further crypto money-service-business revocation waves. Separately, domestic uptake of the newly adopted Financial Action Task Force offshore virtual-asset service provider and stablecoin guidance, expected around 2027, is the most likely channel through which FINTRAC could close the registration and travel-rule gap that the Heleket migration currently exploits.

Judgment: AMF Quebec's crypto-exposure capital/liquidity guidelines for regulated deposit institutions and insurers entered into force 1 July 2026, following a 21 May 2026 publication and a Feb-Mar 2026 consultation. Probable
Cumulative analysis

Crypto, Digital Assets, and Financial Innovation — Cumulative Analysis

The cumulative picture in this domain, established through this baseline, is one of improving Canadian enforcement intensity running alongside a structurally unresolved circumvention pattern. FINTRAC record penalty of close to 176 million Canadian dollars against Xeltox Enterprises, operating as Cryptomus, for failure to file suspicious transaction reports on flows linked to child sexual abuse material, fraud, ransomware and sanctions evasion, stands as the largest penalty on record and is being appealed, with the outcome pending and carrying potential precedent for future penalty quantum. This action sits alongside a broader supervisory drive that has revoked approximately thirty-five crypto money-service-business registrations between 2025 and 2026, following investigative reporting on unregistered Toronto-area crypto shops, though an observed enforcement lag, since some registrations had already expired since 2024, moderates confidence in the deterrent weight of the revocation wave in isolation.

The most consequential structural finding across this baseline is that enforcement intensity has not translated into resolved deterrence. On-chain analysis assessed with confidence that Heleket, a no-KYC successor platform, emerged within the same month as the Cryptomus penalty, drawing the same high-risk user base across Nigeria, Russia and India, with illicit-flow share shifting structurally to the unregulated successor. This enforcement-circumvention pattern, in which national action against a foreign-registered money-service business is answered by standing up an ostensibly separate no-KYC entity serving the same customers, is the defining typology to track in this domain going forward. No confirmed regulatory action against Heleket has been identified as of this baseline.

Against this circumvention pattern, the baseline also records a genuine active-defence achievement: Project Atlas and Operation Avalanche, coordinated across the Ontario Provincial Police, the British Columbia Securities Commission and the Quebec Autorite des marches financiers and supported by blockchain analytics, identified over two thousand fraud-linked wallet addresses across fourteen countries and disrupted Ethereum-based scam networks tied to more than seventy million dollars in combined losses. Provincial regulator participation in blockchain-analytics-enabled enforcement is a maturity signal that should be tracked alongside the federal enforcement record in future cycles.

The global backdrop against which this domestic picture should be read is the Financial Action Task Force adoption, at its February 2026 Plenary, of offshore virtual-asset service provider, stablecoin and unhosted-wallet guidance, expected to inform FINTRAC recalibration of registration thresholds and travel-rule enforcement around 2027. This global standard-setting is contextual rather than the lead story for Canada, but it is the most plausible channel through which the registration and travel-rule gap currently exploited by the Heleket migration could eventually be closed.

The domain trajectory is assessed as improving overall, reflecting genuine enforcement intensification, but the Heleket migration means this improvement should not be read as resolution. Future cycles should track the Xeltox appeal outcome, any regulatory or international response to Heleket, further registration revocation waves, and the pace of FINTRAC uptake of the newly adopted Financial Action Task Force guidance.

domain_sub_briefs · D5 · Cumulative analysis
Standing baseline position

AMF Quebec capital and liquidity guidelines for crypto-asset exposures held by regulated deposit institutions and insurers entered into force 1 July 2026.

Periodic updates (1)
11 Aug 2026 · fim-2026-08-05

Crypto / Digital Assets / Financial Innovation

Canada took its most significant step yet toward a purpose-built stablecoin-integrity regime this cycle. The newly enacted Stablecoin Act imposes duties on stablecoin creators and issuers offering services to persons in Canada, with future FINTRAC registration as money-services businesses dealing in virtual currency pending implementing regulations (fim-2026-W32-002). This registration requirement would bring stablecoin issuers formally within the FINTRAC reporting-entity perimeter for the first time, closing a gap in which stablecoin issuance sat outside the standard registration framework that already captures other virtual-currency dealers.

Complementing the FINTRAC registration track, the Bank of Canada is expected to maintain a public registry of stablecoin issuers running parallel to FINTRAC enrolment (fim-2026-W32-010). The dual-registry structure, a central-bank-maintained public list alongside a FINTRAC compliance-registration requirement, is a notable design choice: it creates a market-facing transparency mechanism distinct from, but coordinated with, the AML and CTF supervisory registration, potentially giving counterparties and consumers an independent verification point beyond the FINTRAC registry itself. The regulatory build-out for both mechanisms remains pending, with an estimate from the Department of Finance placing implementing regulations twelve to eighteen months out.

Outlook

The coming-into-force regulations implementing FINTRAC registration and the Bank of Canada public issuer registry are expected around 2027, a multi-year uncertainty band; until published, stablecoin issuers serving persons in Canada, including those reachable from Quebec, face statutory duties without settled registration mechanics. Watch for any interim guidance bridging the enacted statutory duty and the pending registration architecture.

D6 Compliance Technology & Active Defence

no_changeno_changestanding position

Compliance Technology and Active Defence

Two findings define this domain this cycle, pulling in opposite directions on the question of financial-intelligence and active-defence capacity. The first is a persistent structural constraint: FINTRAC lacks statutory authority to compel additional information from reporting entities beyond voluntary submissions, a constitutional and privacy-driven constraint identified in the 2016 mutual evaluation that continues to limit the depth of financial-intelligence analysis available to law enforcement. This is best read as a genuine capacity deficit rather than a policy choice, consistent with the enabler-jurisdiction filter distinction between constrained capacity and deliberate permissiveness applied elsewhere in this baseline. The practical effect is that FINTRAC financial-intelligence output is bounded by what reporting entities choose to submit voluntarily, a limitation that compounds the supervisory gaps already identified in the notary carve-out and designated-non-financial-business-and-profession sectors, since neither expanded compulsion powers nor full sectoral coverage exists to close the gap from either direction.

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Set against this capacity constraint is a demonstrated active-defence capability. Project Atlas and Operation Avalanche, coordinated by the Ontario Provincial Police, the British Columbia Securities Commission and the Quebec Autorite des marches financiers, used blockchain analytics to identify over two thousand fraud-linked wallet addresses across fourteen countries and disrupt Ethereum-based scam networks linked to more than seventy million dollars in combined losses. This operation demonstrates that, notwithstanding the statutory information-compulsion constraint on FINTRAC itself, Canadian law enforcement and provincial regulators can deploy modern blockchain-analytics tooling effectively in a coordinated, multi-agency posture, and that provincial securities regulators such as the Quebec Autorite des marches financiers are active participants in this tooling deployment rather than passive observers of federal enforcement.

The juxtaposition of these two findings is the core analytical point for this domain: Canadian active-defence tooling and multi-agency operational coordination appear genuinely mature, while the underlying statutory architecture for compelling information from reporting entities remains constrained by constitutional and privacy considerations that have not been legislatively revisited since the 2016 mutual evaluation identified them. Active defence, in other words, is compensating operationally for a structural information-compulsion gap that has not been closed at the statutory level.

Outlook

The principal watch item for this domain is whether the pending Canadian fifth-round mutual evaluation effectiveness assessment addresses, or simply re-documents, the FINTRAC information-compulsion capacity constraint identified in 2016. A secondary watch item is whether further blockchain-analytics-enabled multi-agency operations, of the kind demonstrated in Project Atlas and Operation Avalanche, continue to expand provincial regulator participation alongside federal enforcement, which would represent a continued strengthening of operational active-defence capacity even absent statutory reform.

Judgment: No RegTech/compliance-technology development specific to CA-QC surfaced this cycle. Uncertain
Cumulative analysis

Compliance Technology and Active Defence — Cumulative Analysis

This baseline establishes a cumulative picture for the domain defined by a persistent tension between a genuine statutory capacity constraint and a demonstrated operational active-defence capability. The statutory constraint is that FINTRAC lacks authority to compel additional information from reporting entities beyond voluntary submissions, a constitutional and privacy-driven limitation identified in the 2016 mutual evaluation that continues to bound the depth of financial-intelligence analysis available to Canadian law enforcement. This is assessed as a genuine capacity deficit rather than a deliberate policy choice, and it compounds the supervisory gaps already documented elsewhere in this baseline, including the notary carve-out and uneven designated-non-financial-business-and-profession coverage, since neither expanded compulsion powers nor full sectoral reporting coverage exists to close the resulting financial-intelligence gap.

Against this constraint, the baseline records a genuine operational achievement: Project Atlas and Operation Avalanche, coordinated by the Ontario Provincial Police, the British Columbia Securities Commission and the Quebec Autorite des marches financiers, deployed blockchain analytics to identify over two thousand fraud-linked wallet addresses across fourteen countries and disrupt Ethereum-based scam networks tied to more than seventy million dollars in combined losses. This demonstrates that Canadian law enforcement and provincial securities regulators can operate modern analytics tooling effectively in a coordinated, multi-agency posture, notwithstanding the statutory information-compulsion constraint that continues to bound FINTRAC own analytical reach.

The structural point to track across future cycles is that active-defence tooling is operationally compensating for a statutory gap that has not been legislatively revisited since it was first identified in 2016. This is a durable feature of the Canadian compliance-technology landscape rather than a single-cycle development, and it should be read alongside the broader Quebec supervisory-architecture findings established elsewhere in this baseline, including the dual provincial-federal regulatory structure and the beneficial-ownership registry fragmentation, all of which share a common theme of operational or institutional coordination substituting for full statutory harmonisation.

Future cycles should track whether the pending Canadian fifth-round mutual evaluation effectiveness assessment engages directly with the FINTRAC information-compulsion constraint, or simply re-documents it as in 2016, and whether further blockchain-analytics-enabled multi-agency operations continue to expand provincial regulator participation, including further Quebec Autorite des marches financiers involvement, as a marker of continued operational maturity even absent statutory reform.

domain_sub_briefs · D6 · Cumulative analysis

D7 AML/CTF Regime

no_changeno_changestanding position

AML/CTF Regime

Canada's AML/CTF regime recorded a confirmed, tier-one development this cycle that reaches Quebec by inheritance: the Financial Action Task Force and the Asia/Pacific Group adopted Canada's 2026 Mutual Evaluation Report, moving the country from enhanced to regular follow-up, the status it held following its 2016 evaluation, without placing it on a grey list. No CA-QC-specific AML/CTF finding beyond this federal inheritance reached the materiality bar this cycle; the provincial layer carries the federal finding forward absent any identified provincial variance.

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The evaluation's framing is architecture-over-incident rather than enforcement-episode-driven: it reflects an assessment of Canada's standing legal and institutional framework, including the Financial Transactions and Reports Analysis Centre of Canada's strengthened administrative monetary penalty authority, in force since 26 March 2026, rather than any single enforcement action. At the same time, the evaluators identified continuing weaknesses in administrative monetary penalty practice and in standalone money-laundering prosecution, meaning the improved follow-up status is a net improvement against a mixed record rather than a clean bill. This is the kind of balanced reading the three-pillar discipline calls for: an improving structural finding should not be narrated as though enforcement gaps have closed, and the enforcement-versus-enablement picture for Canada is explicitly recorded as mixed even as the structural trajectory is recorded as improving.

The beneficial-ownership transparency credit embedded in the same evaluation connects directly to the AML/CTF regime finding, since BO transparency is one of the structural pillars FATF assessed in reaching its regular-follow-up determination. Quebec's own register characteristics, discussed under beneficial ownership, form part of the backdrop the evaluation drew on, even though the province-specific register claim itself rests on secondary commentary rather than a primary FATF citation naming Quebec specifically.

No sanctions, enabler-jurisdiction, conflict-finance, or compliance-technology finding specific to Quebec was located this cycle, and none is asserted here; their absence from this brief reflects an absence of qualifying signal, not a null finding about those domains.

Outlook

The two markers that would most clearly indicate further consolidation, or regression, of Canada's AML/CTF position are observable progress on administrative monetary penalty enforcement and on standalone money-laundering prosecutions, both named explicitly by the FATF evaluators as continuing weaknesses. Any subsequent evaluation cycle, or any FINTRAC enforcement data reaching this register, would be read against that specific benchmark.

Judgment: No AML/CTF regime-record change specific to CA-QC surfaced this cycle beyond the BO-timeline and MSB-licensing variances already carried in D2/D3. Uncertain
Standing baseline position

Canada (and inherited by CA-QC) placed in FATF regular follow-up per the June 2026 MER, not grey-listed; weaknesses remain in AMP practice and standalone-ML prosecution.

D8 Commercial Activity

watchwatch

Montreal-headquartered payments/fintech commercial moves this cycle: Nuvei secured Payments Association of South Africa authorisation; Brio and Losange Finance announced a merger to form 'Stelle'. Both disclosed via an aggregator newsletter only; no transaction value disclosed.

Judgment: Two Montreal-headquartered payments/fintech commercial events were reported this cycle via an aggregator source only (Nuvei PASA authorisation; Brio/Losange Finance merger), and could not be independently confirmed at primary source. Uncertain
Regulatory horizon
No dated horizon items this cycle. 2 items tracked without a confirmed date.
2 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

FATF Mutual Evaluation Report cites Quebec REQ beneficial-ownership register as a transparency advance.

The REQ register's public search function is cited externally as a positive corporate-transparency feature; this does not change SAR-trigger thresholds or reportable-activity rules for Quebec reporting entities.

1 evidence refs
Compliance

Quebec beneficial-ownership register cited favourably in national FATF evaluation.

The finding supports continued reliance on REQ search as a customer-due-diligence corroboration source, though the underlying FATF text has not yet been independently verified.

1 evidence refs
Board

Canada's FATF evaluation singles out Quebec's beneficial-ownership register as a bright spot within a broader critical assessment.

The provincial-level finding is a positive reputational data point distinct from the federal-level AML gaps the same evaluation raises, relevant to how group-wide Canadian AML posture is understood externally.

1 evidence refs
Risk

Quebec beneficial-ownership transparency assessed as a structural strength in the current FATF cycle.

This is a structural, not episodic, signal regarding corporate-transparency exposure concentration in the Quebec/Canada risk picture, though it rests on secondary reporting pending primary-source confirmation.

1 evidence refs
Audit

REQ beneficial-ownership citation currently rests on secondary reporting pending primary FATF document review.

The evidentiary chain for this finding is incomplete; the primary FATF Mutual Evaluation Report has not been independently retrieved, which is relevant to documentation adequacy for any audit trail referencing this finding.

1 evidence refs
Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo material change found specific to CA-QC this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable; Canada/Quebec is outside the EEA AMLR/6AMLD/AMLA perimeter.
T3 · FATF Grey Listno_changeCanada is not on the FATF grey list; no CA-QC-specific FATF action located this cycle.
T4 · Beneficial-Ownership Register StatuswatchQuebec's REQ 30-day update clock documented at JID level for the first time this cycle as a structural variance against the federal 15-day ISC clock.
T5 · Crypto & Digital-Asset IntegritywatchAMF Quebec crypto capital/liquidity guidelines (in force 1 Jul 2026) and the cryptoasset-ATM MSB licence class (since 1 Apr 2025) documented as depth on the standing Quebec crypto-prudential layer.
T6 · Sanctions Regime Divergenceno_changeSanctions designation and enforcement remain federal; no Quebec-specific divergence located this cycle.
Registers

Enforcement actions

  • 22 Oct 2025
  • 2026-03
  • 12 Nov 2025
  • 19 Aug 2025
  • 29 May 2026
  • 2 Sep 2025
  • FINTRAC imposed a record penalty of nearly CAD $176 million for multiple PCMLTFA violations, including failure to file suspicious transaction reports for transactions with reasonable grounds to suspect laundering tied to CSAM, fraud, ransomware payments and sanctions evasion. 22 Oct 2025
  • FINTRAC struck the registrations of 23 crypto firms after earlier revoking a dozen others, in a stepped-up enforcement drive against unregistered or non-compliant virtual-currency businesses following investigative reporting on unregistered Toronto-area crypto shops. 2026-03
  • Canada announced new sanctions under the Special Economic Measures (Russia) Regulations targeting drone makers and 100 shadow-fleet vessels, announced jointly with Ukraine's foreign minister at a G7 Foreign Ministers meeting in Ontario. 12 Nov 2025
  • Coordinated Canadian law-enforcement/regulatory operations (Project Atlas and Operation Avalanche), supported by blockchain analytics, identified over 2,000 fraud-linked wallet addresses across 14 countries and disrupted Ethereum-based scam networks. 19 Aug 2025

Sanctions changes

  • 23 Oct 2025
  • Canada added new listings under the Special Economic Measures (Russia) Regulations targeting Russian drone manufacturers and 100 vessels identified as part of Russia's shadow fleet, announced at a G7 Foreign Ministers meeting in Ontario. 12 Nov 2025
  • FATF's February 2026 Plenary added Kuwait and Papua New Guinea to its Jurisdictions Under Increased Monitoring list, while Iran, DPRK and Burma remain on the High-Risk Call for Action list — a global list change that Canadian financial institutions must reflect in enhanced due-diligence obligations under FINTRAC guidance. 13 Feb 2026

Regulatory horizon (register)

  • Stablecoin Act coming-into-force regulations
  • FATF 5th-Round Mutual Evaluation of Canada — Effectiveness Assessment
  • Provincial-Federal Beneficial Ownership Registry Interconnection (incl. Quebec)
  • FATF oVASP/Stablecoin Guidance Domestic Uptake by FINTRAC

Active schemes

  • Following a Supreme Court ruling, FINTRAC investigatory and reporting powers over legal counsels, legal firms and Quebec notaries were declared constitutionally inoperative, removing an entire class of high-risk gatekeepers from AML and CFT reporting duties in conveyancing, corporate formation, trust structuring and estate transfers.
  • After the record FINTRAC penalty against Cryptomus and Xeltox, on-chain analysis shows a parallel no-KYC platform, Heleket, emerging within the same month, drawing the same high-risk user base and shifting illicit-flow share structurally to the unregulated successor.
  • Federal and FATF assessments identify real estate and, to a lesser degree, casinos as principal domestic laundering channels, with Montreal named alongside Vancouver and Toronto; proceeds are layered into property purchases, driving price distortion, sustained by disproportionately low suspicious-transaction-report filing.
  • Russian oil and drone-component procurement networks use flag-hopping tankers, opaque intermediary ownership and third-country trading hubs to move sanctioned commodities and dual-use goods while accessing Western trade finance and insurance; Canada responds as a target and coalition member via SEMA designations mirroring EU and UK listings, without automatic cross-jurisdictional recognition of designated vessels or entities.
Sources
  1. Global Affairs Canada
  2. FINTRAC
  3. FATF
  4. FinCEN
  5. We Are Not For Sale (NGO)
  6. Québec Online Gaming Coalition
  7. FATF/APG
  8. Insight Threat Intel (newsletter)
  9. FINTRAC
  10. Blakes (law firm)
  11. McMillan LLP
  12. https://www.amlintelligence.com/2026/09/latest-fatf-praises-canadas-aml-progress-but-flags-key-professional-money-laundering-gaps/
  13. https://www.acams.org/en/news/canada-envisions-aml-upgrade-before-fatf-arrives
  14. Éditeur officiel du Québec / CanLII
  15. 2727 Coworking
  16. Coincub
  17. Finance et Investissement
  18. Autorité des marchés financiers (Québec)
  19. Fathom4sight newsletter
  20. Canada's measures to combat money laundering and terrorist financing
  21. Mutual Evaluation of Canada
  22. Cryptomus: Crypto Payment Processor Risk Profile | TRM Labs
  23. Documents - Financial Action Task Force (FATF)
  24. Canada
  25. September 2016 Anti-money laundering and counter-terrorist financing measures
  26. Canada revokes dozens of crypto firms' registrations - ICIJ
  27. Crypto regulatory affairs: EU sanctions target A7A5 Ruble-backed stablecoin
  28. READOUT: FinCEN and Partner FIU Officials Meet in Canada for International Public-Private Partnership Events on Illicit Finance | FinCEN.gov
  29. Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on
  30. Money laundering and terrorist financing risks
  31. National money laundering and terrorist financing risk assessment
  32. Money Laundering National Risk Assessment Guidance
  33. Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures
  34. FATF GUIDANCE Money Laundering National Risk Assessment Guidance
  35. fatf Guidance National Money Laundering and Terrorist Financing Risk Assessment
  36. MONEY LAUNDERING NATIONAL RISK ASSESSMENT TOOLKIT – ANNEXES A-C
  37. FATF launches National Risk Assessment toolkit to help countries identify greatest money laundering risks
  38. Autorité des marchés financiers (AMF) | EU Digital Finance Platform
  39. US and Canada Join Forces to Combat Crypto Scams - Chainalysis
  40. Médiateur de l'autorité des marchés financiers (AMF) - European Commission
  41. Canada's measures to combat money laundering and terrorist financing
  42. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  43. Lutte contre le financement des rançongiciels
  44. NATIONS UNIES Office contre la drogue et le crime FONDS MONÉTAIRE
  45. Canada: Real-Estate Firms Violate Anti-Money Laundering Rules | OCCRP
  46. Canada Dismantles Major Money Laundering Network | OCCRP
  47. Canada Dismantles Major Money Laundering Network
  48. Canada to Fight Laundering of Drug Money through Casinos | OCCRP
  49. Following a Trail of Tainted Money From China Into Vancouver Real Estate | OCCRP
  50. Province of British Columbia is Canada’s Crime, Money Laundering Hub | OCCRP
  51. FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING FATF | FinCEN.gov
  52. Canada: Montreal Mayor Charged With Fraud | OCCRP
  53. Guidance-Beneficial-Ownership-Transparency-Legal- ...
  54. Guidance on Beneficial Ownership and Transparency of Legal Arrangements
  55. Quick Reference | FinCEN.gov
  56. Guidance on Beneficial Ownership of Legal Persons
  57. U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov
  58. NGOs Praise Canada’s New Corporate Ownership Registry | OCCRP
  59. Strategy guidance note on beneficial ownership registries
  60. Réseau de répression des crimes financiers
  61. Canada poised to create public company registry to curb financial secrecy - ICIJ
  62. Guidance on Transparency and Beneficial Ownership
  63. Crypto Regulation and Illicit Finance in Canada – White Paper | TRM Labs
  64. APPENDIx E – CROSS-BORDER FUNDS TRANSFER ...
  65. Financial Crimes Enforcement Network 71 U.S. Department of the Treasury
  66. Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  67. Enforcement Actions | FinCEN.gov
  68. Special Measures | FinCEN.gov
  69. Binance Fined by Canada’s FINTRAC for Breaching Money-Laundering Protections - Bloomberg
  70. Provinces pose threat to Canada’s bid to curb corporate secrecy, researchers warn - ICIJ
  71. BOI E-FILING - FinCEN
  72. Frequently Asked Questions | FinCEN.gov
  73. Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ
  74. FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance | FinCEN.gov
  75. Beneficial Ownership Information Report (BOIR) - BOI E-FILING
  76. EU adopts 19th package of sanctions against Russia - Finance
  77. Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks | TRM Labs
  78. 1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network
  79. Venture capital firm hit with $216 million penalty for ‘egregious’ violations of US sanctions against Russian billionaire - ICIJ
  80. Canada sanctions 10 Putin allies, including Russia’s leading TV propagandists - ICIJ
  81. EU sanctions against Russia: questions and answers - Consilium
  82. Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium
  83. 19th package of sanctions against Russia: EU targets Russian energy, third-country banks and crypto providers - Consilium
  84. Timeline - EU sanctions against Russia - Consilium
  85. Russia's war of aggression against Ukraine: Council sanctions 9 shadow fleet enablers - Consilium
  86. Sanctions Programs and Country Information | Office of Foreign Assets Control
  87. Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control
  88. US, Canada Target Russia with Hundreds of Sanctions | OCCRP
  89. Questions and answers on the 20th package of sanctions against Russia
  90. Canada Sanctions Russian Drone Makers, ‘Shadow Fleet’ Vessels - Bloomberg
  91. Recent Actions | Office of Foreign Assets Control
  92. Russian Harmful Foreign Activities Sanctions
  93. Transnational Criminal Organizations Designations; Issuance of Amended Russia-related General Licenses; Publication of Updated Russia-related Frequently Asked Questions | Office of Foreign Assets Control
  94. Crypto-actifs: comment l'UE réglemente les marchés - Consilium
  95. NORMES INTERNATIONALES SUR LA LUTTE CONTRE LE BLANCHIMENT DE
  96. 2025 Crypto Regulatory Round-Up
  97. Crypto Sanctions: 2026 Crypto Crime Report
  98. How crypto regulation changed in 2025: a global review
  99. Canada Issues Money Laundering Indicators For Cryptoassets
  100. Crypto-actifs, criminalité et régulations - 2025 l'année charnière
  101. FINTRAC LTD overview - Find and update company information - GOV.UK
  102. 1 UNCLASSIFIED | NON CLASSIFIÉ
  103. FinCEN Year In Review | FinCEN.gov
  104. Public Consultation - FATF Risk-Based Guidance on Recommendation 25
  105. Beneficial Ownership
  106. Best Practices on Beneficial Ownership for Legal Persons
  107. Revision of Recommendation 25 - White Paper for Public Consultation
  108. BENEFICIAL OWNERSHIP OF LEGAL PERSONS MARCH 2023 MARCH 2023
  109. Interim Final Rule: Questions and Answers | FinCEN.gov
  110. FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov
  111. Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov
  112. Assessments
  113. Mutual Evaluations
  114. Calendars
  115. Outcomes of meetings
  116. Events
  117. Outcomes FATF Plenary, 11-13 February 2026
  118. 2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG
  119. Consolidated assessment ratings
  120. Global Affairs Canada | OCCRP
  121. Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control
  122. Haiti: EU lists three individuals and renews sanctions regime for an additional year - Consilium
  123. Sanctions | Security Council
  124. United Nations Security Council Consolidated List | Security Council
  125. Security Council Speakers Call for Rigorous Sanctions Compliance to Address Multidimensional Crisis in Haiti | UN Meetings Coverage and Press Releases
  126. The UK Sanctions List - GOV.UK
  127. Belarus Sanctions | Office of Foreign Assets Control
  128. Sanctions List Updates
  129. FATF/APG
  130. FATF
  131. Department of Finance Canada
  132. UNODC / Government of Canada
  133. FinCEN (U.S. Department of the Treasury)
  134. TRM Labs
  135. Elliptic
  136. ICIJ / Toronto Star
  137. OCCRP
  138. Bloomberg
  139. ICIJ
  140. Chainalysis
  141. Council of the European Union
Coverage gaps
fim-int-2026-07-05-G001: Direct primary-source confirmation …
fim-int-2026-07-05-G001: Direct primary-source confirmation of any post-2016 legislative or judicial reconsideration of the Quebec notary and legal-counsel AML carve-out would clarify whether the gap remains fully unaddressed heading into the pending fifth-round mutual evaluation. [resolved]
fim-int-2026-07-05-G002: A direct FINTRAC statement or legis…
fim-int-2026-07-05-G002: A direct FINTRAC statement or legislative proposal on expanding its authority to compel additional information from reporting entities would clarify whether the 2016-identified capacity deficit has been legislatively addressed. [resolved]
fim-int-2026-07-05-G003: Updated real estate and casino sect…
fim-int-2026-07-05-G003: Updated real estate and casino sector suspicious-transaction-report filing statistics from after 2020 would clarify whether the Montreal real estate laundering nexus has narrowed or persisted at comparable scale. [resolved]
fim-int-2026-07-05-G004: A direct primary-source publication…
fim-int-2026-07-05-G004: A direct primary-source publication from the Quebec Registraire des entreprises confirming or denying any commitment to align with the federal CBCA beneficial-ownership disclosure standard would resolve current uncertainty on registry harmonisation timing. [resolved]
fim-int-2026-07-05-G005: Direct retrieval of an Autorite des…
fim-int-2026-07-05-G005: Direct retrieval of an Autorite des marches financiers Quebec or Registraire des entreprises du Quebec primary publication would close the residual sub-national sourcing-floor gap currently bridged via national-level FATF and Government of Canada documents. [resolved]
fim-int-2026-07-14-G001: obligation_refs.framework closed en…
fim-int-2026-07-14-G001: obligation_refs.framework closed enum lacks a Canada-specific PCMLTFA value, preventing accurate obligation-citation classification for CA-QC AML claims this cycle. [resolved]
fim-int-2026-07-14-G002: No CA-QC-specific D1 (sanctions), D…
fim-int-2026-07-14-G002: No CA-QC-specific D1 (sanctions), D3 (enabler jurisdiction), or D4 (conflict finance) evidence was identified this cycle in a jurisdiction-bound research pass. [resolved]
fim-int-2026-07-14-G003: Tier-D watch jurisdictions (KH/LA/M…
fim-int-2026-07-14-G003: Tier-D watch jurisdictions (KH/LA/MX/CO) were not searched this cycle given the CA-QC jurisdiction-bound scope; flagged for correction in the next full-sweep cycle. [resolved]
fim-int-2026-07-14-G004: No Tier-1 primary legislative text …
fim-int-2026-07-14-G004: No Tier-1 primary legislative text for Bill C-12/Bill C-29 was directly cited this cycle; confidence capped via convergent Tier-2/4 secondary law-firm reporting rather than Justice Laws Canada primary text. [resolved]
fim-int-2026-08-05-G001: No independent regulator (FINTRAC/R…
fim-int-2026-08-05-G001: No independent regulator (FINTRAC/RACJ) quantification located for Quebec's estimated 2,000 unlicensed gambling sites or $300M tax-leakage claim; both figures rest on interested-party sources. [resolved]
fim-int-2026-08-05-G002: No material 2026-specific update lo…
fim-int-2026-08-05-G002: No material 2026-specific update located for Laos or Colombia Tier-D coverage beyond standing FATF follow-up posture. [resolved]
fim-int-2026-08-05-G003: FIM's sanctions_changes issuing_bod…
fim-int-2026-08-05-G003: FIM's sanctions_changes issuing_body closed enum (OFAC|OFSI|EU_Council|UN) does not cover Canadian autonomous sanctions (Global Affairs Canada/SEMA); three confirmed Canadian sanctions amendments could not be encoded in sanctions_changes[] without misclassifying the issuing body, so they are recorded via structured_claims and domain_tracker instead. [resolved]
fim-int-2026-08-05-G004: No Tier-1 OFAC primary source direc…
fim-int-2026-08-05-G004: No Tier-1 OFAC primary source directly retrieved this cycle for the Kok An (Cambodia) designation; reliance on secondary NGO/trade-press reporting caps confidence at Assessed. [resolved]
fim-int-2026-10-11-G001: No primary CAI/REQ statement was re…
fim-int-2026-10-11-G001: No primary CAI/REQ statement was reached this cycle confirming the public-searchability and verification-gap characterization of Quebec's beneficial-ownership register; the claim rests solely on T3 law-firm commentary. [resolved]
fim-int-2026-10-11-G002: Tier D jurisdiction watch (Cambodia…
fim-int-2026-10-11-G002: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) was not actively searched this cycle; pooled union search budget was prioritized to the bound jurisdiction. [resolved]
fim-int-2026-10-11-G003: No D1 Sanctions, D3 Enabler Jurisdi…
fim-int-2026-10-11-G003: No D1 Sanctions, D3 Enabler Jurisdictions, D4 Conflict Finance, or D6 Compliance Technology finding specific to CA-QC was located this cycle. [resolved]
fim-int-2026-10-18-G001: FATF Mutual Evaluation Report full …
fim-int-2026-10-18-G001: FATF Mutual Evaluation Report full text was not directly retrieved this cycle; the REQ-register finding rests on T2 secondary reporting only. [open]
fim-int-2026-10-18-G002: Tier D jurisdictions (KH, LA, MX, C…
fim-int-2026-10-18-G002: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle; budget was concentrated on the bound jurisdiction. [open]
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No CA-QC-specific D1 sanctions-evasion architecture development was located this cycle. [open]
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No CA-QC-specific D4 conflict finance development was located this cycle. [open]
fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D8'}): Montreal fintech commercial moves (Nuvei PASA authorisation; Brio/Losange Finance merger) rest only on a T4 aggregator source; primary press releases would upgrade confidence. [open]
FIM-GAP-001 (D2): Legal counsels, legal firms and Quebec not…
FIM-GAP-001 (D2): Legal counsels, legal firms and Quebec notaries remain excluded from AML/CFT supervision following a Supreme Court ruling declaring FINTRAC's information-gathering powers over the legal profession unconstitutional; this carve-out remains unresolved heading into the 5th-round MER.
FIM-GAP-002 (D6): FINTRAC lacks authority to request additio…
FIM-GAP-002 (D6): FINTRAC lacks authority to request additional information from reporting entities beyond what is voluntarily submitted, a constitutional-privacy-driven constraint identified in the 2016 MER that limits the depth of financial-intelligence analysis available to law enforcement.
FIM-GAP-003 (D2): Real estate and casino sectors continue to…
FIM-GAP-003 (D2): Real estate and casino sectors continue to show comparatively low suspicious-transaction-report filing rates and inconsistent supervisory intensity; Montreal is repeatedly named alongside Vancouver and Toronto as a hub for real-estate-based laundering.
FIM-GAP-004 (D2): Beneficial ownership transparency remains …
FIM-GAP-004 (D2): Beneficial ownership transparency remains fragmented across Canada's federal-provincial structure; the federal CBCA registry covers only federally incorporated companies, while most Canadian companies — including those registered via Quebec's provincial registrar — fall outside its scope, and provincial/territorial registries were found to collect inconsistent, often minimal beneficial-ownership data.
FIM-GAP-005 (D3): This baseline could not independently retr…
FIM-GAP-005 (D3): This baseline could not independently retrieve a Quebec-specific provincial regulatory primary source (e.g., a direct Autorité des marchés financiers du Québec or Registraire des entreprises du Québec publication) within the research window; Quebec-specific findings are instead substantiated via national-level FATF and Government of Canada documents that explicitly discuss the Quebec carve-out and provincial registry fragmentation.

Evidence

Confidence-tiered claims

FATF/APG adopted Canada's 2026 Mutual Evaluation Report (Plenary June 2026, published 29 Sept 2026); Canada not grey-listed, placed in regular follow-up (improved from enhanced follow-up), crediting beneficial-ownership transparency progress. [Source 1]
Probable · 1 source
Quebec's REQ ultimate-beneficiary register (Bill 78 amendments, in force 2023-03-31) is cited by commentary as a freely and publicly searchable register, broader in public access than the federal CBCA register, though it retains a 25% control threshold and no independent verification of filer-submitted data. [Source 1]
Probable · 1 source
TAMF held that digital-asset tokens traded on decentralized exchanges did not meet the investment-contract test (reasoning drawn from the US Ripple decision), while upholding findings of unregistered-securities sales via a pump-and-dump scheme. [Source 1]
Uncertain · 1 source
Canada's FATF Mutual Evaluation Report cites Quebec's REQ public beneficial-ownership register (required disclosure since 31 March 2023, public name-based search since 31 July 2024) as a corporate-transparency advance. [Source 1]
Probable · 1 source
30 days of a change [Source 1]
Probable · 1 source
Revenu Quebec, since 13 September 2021, with a cryptoasset-ATM licence class since 1 April 2025 [Source 1]
Probable · 1 source
2026-07-01 [Source 1]
Probable · 1 source
Nuvei secured PASA authorisation in South Africa; Brio and Losange Finance announced a merger to form Stelle [Source 1]
Uncertain · 1 source