--- title: "Canada — Quebec (CA-QC) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/canada-quebec/ source_html: /jurisdictions/canada-quebec/index.html description: "Financial integrity intelligence for Canada – Quebec (CA-QC): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: ca5151bf083382dcd957583f85f6f2cb0ef135534320f0a69b3cb8860c33a899 generator: "fe-fleet/md-twin@1.0" --- # Canada — Quebec (CA-QC) — Financial-Integrity Intelligence · Sentinel 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). More A 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](/jurisdictions/ca/) 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) #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 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) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change found specific to CA-QC this cycle. T2 · EU AML Package / AMLA no_change Not applicable; Canada/Quebec is outside the EEA AMLR/6AMLD/AMLA perimeter. T3 · FATF Grey List no_change Canada is not on the FATF grey list; no CA-QC-specific FATF action located this cycle. T4 · Beneficial-Ownership Register Status watch Quebec'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 Integrity watch AMF 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 Divergence no_change Sanctions 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. 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[Crypto Regulation and Illicit Finance in Canada – White Paper | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/crypto-regulation-and-illicit-finance-in-canada) - [APPENDIx E – CROSS-BORDER FUNDS TRANSFER ...](https://www.fincen.gov/sites/default/files/shared/Appendix_E.pdf) - [Financial Crimes Enforcement Network 71 U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/Appendix_E.pdf) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Binance Fined by Canada’s FINTRAC for Breaching Money-Laundering Protections - Bloomberg](https://www.bloomberg.com/news/articles/2024-05-09/binance-fined-4-4-million-by-canada-watchdog-for-rule-breaches) - [Provinces pose threat to Canada’s bid to curb corporate secrecy, researchers warn - ICIJ](https://www.icij.org/investigations/pandora-papers/provinces-pose-threat-to-canadas-bid-to-curb-corporate-secrecy-researchers-warn/) - [BOI E-FILING - FinCEN](https://boiefiling.fincen.gov/) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-initial-beneficial-ownership-information-reporting-guidance) - [Beneficial Ownership Information Report (BOIR) - BOI E-FILING](https://boiefiling.fincen.gov/fileboir) - [EU adopts 19th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-19th-package-sanctions-against-russia-2025-10-23_en) - [Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks | TRM Labs](https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks) - [1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/753-red-alert-shadow-fleet-sanctions-evasion-and-avoidance-network/file) - [Venture capital firm hit with $216 million penalty for ‘egregious’ violations of US sanctions against Russian billionaire - ICIJ](https://www.icij.org/news/2025/07/venture-capital-firm-hit-with-216-million-penalty-for-egregious-violations-of-us-sanctions-against-russian-billionaire/) - [Canada sanctions 10 Putin allies, including Russia’s leading TV propagandists - ICIJ](https://www.icij.org/investigations/russia-archive/canada-sanctions-10-putin-allies-including-russias-leading-tv-propagandists/) - [EU sanctions against Russia: questions and answers - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/) - [Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/russia-s-war-of-aggression-against-ukraine-council-sanctions-41-vessels-of-the-russian-shadow-fleet/) - [19th package of sanctions against Russia: EU targets Russian energy, third-country banks and crypto providers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/) - [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [Russia's war of aggression against Ukraine: Council sanctions 9 shadow fleet enablers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/russia-s-war-of-aggression-against-ukraine-council-sanctions-9-shadow-fleet-enablers/) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [US, Canada Target Russia with Hundreds of Sanctions | OCCRP](https://www.occrp.org/en/news/us-canada-target-russia-with-hundreds-of-sanctions) - [Questions and answers on the 20th package of sanctions against Russia](https://ec.europa.eu/commission/presscorner/detail/en/qanda_26_876) - [Canada Sanctions Russian Drone Makers, ‘Shadow Fleet’ Vessels - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-12/canada-sanctions-russian-drone-makers-shadow-fleet-vessels) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626) - [Transnational Criminal Organizations Designations; Issuance of Amended Russia-related General Licenses; Publication of Updated Russia-related Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251217) - [Crypto-actifs: comment l'UE réglemente les marchés - Consilium](https://www.consilium.europa.eu/en/policies/crypto-assets-how-the-eu-is-regulating-markets/) - [NORMES INTERNATIONALES SUR LA LUTTE CONTRE LE BLANCHIMENT DE](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Recommandations%20du%20GAFI%202012.pdf.coredownload.pdf) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Canada Issues Money Laundering Indicators For Cryptoassets](https://www.elliptic.co/blog/canada-issues-money-laundering-and-terrorist-financing-indicators-for-crypto) - [Crypto-actifs, criminalité et régulations - 2025 l'année charnière](https://event.trmlabs.com/frenchgovernmentblockintbriefi) - [FINTRAC LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/15818965) - [1 UNCLASSIFIED | NON CLASSIFIÉ](https://www.unodc.org/documents/treaties/CAE_IEG/Questionnaire_responses/Canada_2026-02-02.pdf) - [FinCEN Year In Review | FinCEN.gov](https://www.fincen.gov/about-fincen/fincen-year-review) - [Public Consultation - FATF Risk-Based Guidance on Recommendation 25](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/R25-Public-Consultation-Oct-23.html) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [Best Practices on Beneficial Ownership for Legal Persons](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Best-practices-beneficial-ownership-legal-persons.html) - [Revision of Recommendation 25 - White Paper for Public Consultation](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/R25-public-consultation.html) - [BENEFICIAL OWNERSHIP OF LEGAL PERSONS MARCH 2023 MARCH 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf) - [Interim Final Rule: Questions and Answers | FinCEN.gov](https://www.fincen.gov/boi/ifr-qa) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Calendars](https://www.fatf-gafi.org/en/calendars.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [Events](https://www.fatf-gafi.org/en/calendars/events.html) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Global Affairs Canada | OCCRP](https://www.occrp.org/en/organizations/global-affairs-canada) - [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](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Haiti: EU lists three individuals and renews sanctions regime for an additional year - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/07/15/haiti-eu-lists-three-individuals-and-renews-sanctions-regime-for-an-additional-year/) - [Sanctions | Security Council](https://main.un.org/securitycouncil/en/sanctions/information) - [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list) - [Security Council Speakers Call for Rigorous Sanctions Compliance to Address Multidimensional Crisis in Haiti | UN Meetings Coverage and Press Releases](https://press.un.org/en/2025/sc16247.doc.htm) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [Belarus Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/belarus-sanctions) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [FATF/APG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-canada-2016.html) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Canada.html) - [Department of Finance Canada](https://www.canada.ca/en/department-finance/programs/financial-sector-policy/nira-neri/2025/report.html) - [UNODC / Government of Canada](https://www.unodc.org/documents/treaties/CAE_IEG/Questionnaire_responses/Canada_2026-02-02.pdf) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [TRM Labs](https://www.trmlabs.com/resources/intel-library/cryptomus) - [Elliptic](https://www.elliptic.co/blog/crypto-regulatory-affairs-eu-sanctions-target-a7a5-ruble-backed-stablecoin) - [ICIJ / Toronto Star](https://www.icij.org/investigations/coin-laundry/canada-revokes-dozens-of-crypto-firms-registrations/) - [OCCRP](https://occrp.org/en/daily/11760-canada-real-estate-firms-violate-anti-money-laundering-rules) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-11-12/canada-sanctions-russian-drone-makers-shadow-fleet-vessels) - [ICIJ](https://www.icij.org/investigations/pandora-papers/provinces-pose-threat-to-canadas-bid-to-curb-corporate-secrecy-researchers-warn/) - [Chainalysis](https://www.chainalysis.com/blog/us-and-canada-join-forces-to-combat-crypto-scams/) - [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source 30 days of a change [[Source 1]](#sec-sources) Probable · 1 source Revenu Quebec, since 13 September 2021, with a cryptoasset-ATM licence class since 1 April 2025 [[Source 1]](#sec-sources) Probable · 1 source 2026-07-01 [[Source 1]](#sec-sources) Probable · 1 source Nuvei secured PASA authorisation in South Africa; Brio and Losange Finance announced a merger to form Stelle [[Source 1]](#sec-sources) Uncertain · 1 source