--- title: "Canada (CA) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/canada/ source_html: /jurisdictions/canada/index.html description: "Financial integrity intelligence for Canada (CA): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: b8dfa6e02b0d361f263199f209fb00463f0c435822b8d28d08ca90ca26933f11 generator: "fe-fleet/md-twin@1.0" --- # Canada (CA) — 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 CA Domains covered 8 of 8 Sources 204 Role actions 8 Horizon <90d 3 Jurisdiction profile FATF status: Largely Compliant Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed Canada's AML/CTF/CPF regime rests on the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), enforced by FINTRAC as FIU/supervisor. More June 2024 PCMLTFA amendments expanded FINTRAC's information-sharing powers. A federal public beneficial-ownership registry (Bill C-42, CBCA amendment) operates alongside fragmented provincial corporate registries. A 2015 Supreme Court ruling exempts legal counsel and Quebec notaries from AML obligations, a persistent structural gap FATF has repeatedly flagged. Key deficiencies - Constitutional exemption of legal counsel, law firms and Quebec notaries from AML/CFT obligations following Federation of Law Societies of Canada v. Canada - Historic FINTRAC under-disclosure of actionable intelligence to law enforcement (Cullen Commission finding) - Provincial/territorial corporate registry fragmentation undermining the federal beneficial-ownership registry - Uneven supervisory intensity across DNFBPs and money services/virtual-asset businesses relative to banking, securities and insurance Recent developments (18m) - June 2026 FATF Plenary adopted the joint FATF-APG 5th-round Mutual Evaluation Report of Canada, for publication September-October 2026 - FINTRAC assessed a record ~CAD 177 million penalty against Xeltox Enterprises Ltd. (Cryptomus), a Vancouver-based, Russia-linked crypto payment processor (October 2025) - FINTRAC revoked registrations of dozens of crypto/money-services businesses in a stepped-up enforcement campaign (late 2025-early 2026) - Canada sanctioned Russian drone manufacturers and 100 'shadow fleet' vessels alongside G7 partners (November 2025) ## Member jurisdictions This page covers Canada federal law once. Each member’s page covers its own law, regulators and enforcement (5 of 7 members covered here). - [Canada – Alberta](/jurisdictions/ca-ab/) - [Canada – British Columbia](/jurisdictions/ca-bc/) - [Canada – New Brunswick](/jurisdictions/ca-nb/) - [Canada – Ontario](/jurisdictions/ca-on/) - [Canada – Quebec](/jurisdictions/ca-qc/) Brief ## Lead signal #### Lead Signal Canada published draft Stablecoin Regulations on 24 October 2026, operationalising the federal Stablecoin Act, which received royal assent on 26 March 2026. The draft regulations, carried in the Canada Gazette, would require non-financial-institution issuers of fiat-backed stablecoins offered to Canadians to register with the Bank of Canada, hold reserve assets at a 1:1 ratio in high-quality liquid assets, offer redemption within three business days, cap redemption fees at 1% of the redemption amount, and comply with a ban on holding-based yield, subject to a narrow transaction-linked rewards carve-out. The draft regulations also amend the Retail Payment Activities Regulations to bring payment service providers that move prescribed stablecoins within Bank of Canada supervision under the Retail Payment Activities Act, pending a further Governor-in-Council commencement order. A 60-day consultation period runs to 23 December 2026, with an in-force target of fall 2027. This represents Canada's move from indirect, securities-law-mediated oversight of stablecoins toward a dedicated federal prudential and conduct perimeter administered by its central bank. Read full brief #### Lead Signal Canada published draft Stablecoin Regulations on 24 October 2026, operationalising the federal Stablecoin Act, which received royal assent on 26 March 2026. The draft regulations, carried in the Canada Gazette, would require non-financial-institution issuers of fiat-backed stablecoins offered to Canadians to register with the Bank of Canada, hold reserve assets at a 1:1 ratio in high-quality liquid assets, offer redemption within three business days, cap redemption fees at 1% of the redemption amount, and comply with a ban on holding-based yield, subject to a narrow transaction-linked rewards carve-out. The draft regulations also amend the Retail Payment Activities Regulations to bring payment service providers that move prescribed stablecoins within Bank of Canada supervision under the Retail Payment Activities Act, pending a further Governor-in-Council commencement order. A 60-day consultation period runs to 23 December 2026, with an in-force target of fall 2027. This represents Canada's move from indirect, securities-law-mediated oversight of stablecoins toward a dedicated federal prudential and conduct perimeter administered by its central bank. #### Other Developments FINTRAC enforcement intensity rose sharply in 2025-26. Canada's financial-intelligence unit reported 35 notices of violation worth more than CA$247 million in its 2025-26 results, a 52% increase in notice count over the prior year's 23 notices worth CA$25 million. Money-services-business registration revocations were concentrated in the virtual-currency sector, with third-party trade-press tracking indicating roughly 76% of 165 MSB registration revocations in 2026 involved businesses offering virtual-currency services. This pattern places sustained enforcement pressure specifically on crypto-asset-handling reporting entities operating under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, which remains the standing statutory basis for Canada's AML/CTF regime, administered by FINTRAC and consolidated current to 21 July 2026 with amendments dated 26 March 2026. #### Cross-Monitor Connections The emergence of a dedicated federal stablecoin perimeter, layered onto a financial-intelligence unit that is simultaneously intensifying enforcement specifically against virtual-currency reporting entities, signals a coordinated tightening of Canada's digital-asset financial-integrity architecture from two directions at once: prudential design at the point of issuance, and AML/CTF enforcement at the point of ongoing reporting-entity compliance. For readers tracking payments-infrastructure regulation, the same draft Stablecoin Regulations extend Retail Payment Activities Act supervision to PSPs moving prescribed stablecoins, meaning this is simultaneously a payments-regulatory development and a financial-integrity one. For readers tracking consumer-facing digital-asset and gambling-adjacent commercial activity in Canada, the enforcement intensity against virtual-currency MSBs is relevant underlying context for any crypto-sector entity seeking MSB registration in this period. #### Outlook The 60-day consultation on the draft Stablecoin Regulations, closing 23 December 2026, is the principal near-term event: industry submissions may alter the registration, reserve, redemption or fee terms before the regulations proceed toward their targeted fall 2027 in-force date. The Retail Payment Activities Regulations extension to stablecoin-moving PSPs will separately require a Governor-in-Council commencement order before taking effect, a distinct procedural step from the core stablecoin registration regime. FINTRAC's 2025-26 enforcement results, with their pronounced concentration on virtual-currency MSBs, suggest continued elevated scrutiny of crypto-asset reporting entities is likely to persist into the period when the new stablecoin regime comes into force, creating a compounding compliance burden for virtual-currency businesses operating in Canada. Earlier periodic briefs (5) 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Canada has completed its fifth-round FATF/APG mutual evaluation, with the published report placing the country in regular follow-up rather than enhanced follow-up and recording upgrades across a cluster of technical-compliance ratings, including Recommendation 17 moving from non-compliant to compliant and Recommendations 12, 15 and 23 moving from non-compliant to largely compliant. Recommendation 8, covering non-profit organisations, also improved from partially compliant to largely compliant. The evaluation nonetheless flags that beneficial-ownership transparency, while considerably advanced at the federal level through the Innovation, Science and Economic Development Canada corporate registry, remains undercut in practice by uneven implementation across provinces and territories, several of which have no comparable transparency-register legislation of their own. This is an architecture finding rather than an incident: Canada has built a federal instrument that functions as designed, but the jurisdiction as a whole is only as transparent as its most permissive province, and the mutual evaluation says so explicitly. #### Other Developments A substantial AML/CTF enforcement overhaul received Royal Assent in March 2026. Bill C-12 together with the Budget 2025 Implementation Act (Bill C-15) raises the ceilings on FINTRAC administrative monetary penalties considerably, introduces compliance orders and mandatory compliance agreements as new supervisory tools, and lays the groundwork for universal reporting-entity enrolment and a dedicated Stablecoin Act. The precise AMP figures diverge between the commentary sources available this cycle, with one citing a serious-violation ceiling of CAD 4,000,000 and another citing CAD 4,000,000 for individuals and CAD 20,000,000 for entities; no consolidated regulation text was retrieved to reconcile the two this cycle, so both figures are carried as reported rather than resolved. Critically, universal enrolment and the Stablecoin Act are both enacted but not yet in force, pending implementing regulations, so the practical reach of the overhaul will depend on a regulatory timetable not yet published. Canada's federal beneficial-ownership registry continues to operate as the backbone of the corporate-transparency regime. Since October 2025, FINTRAC-regulated reporting entities dealing with federally incorporated businesses have been required to compare the beneficial-ownership information they collect against the Innovation, Science and Economic Development Canada registry and report material discrepancies. This cross-checking obligation is precisely the kind of effectiveness-oriented mechanism the FATF evaluation credits, even as it notes that the mechanism's reach stops at the federal incorporation boundary. Reported FINTRAC enforcement figures against crypto-asset platforms Cryptomus and KuCoin could not be corroborated this cycle. Secondary reporting cites penalties in the region of CAD 126 million and CAD 14 million respectively, but these figures rest on a single tier-four source and have not been checked against FINTRAC's own enforcement decisions register. The standing crypto-AML architecture otherwise persists unchanged: the Crypto-Asset Reporting Framework has applied since January 2026, and the Canadian Investment Regulatory Organization's digital-asset custody framework has applied since February 2026. #### Cross-Monitor Connections The PCMLTFA overhaul and the Stablecoin Act sit directly at the intersection of this monitor's AML/CTF regime finding and the World Payments Monitor's stablecoin and digital-money tracking: both enacted-but-not-in-force instruments will, once implementing regulations are published, create new FINTRAC registration obligations for stablecoin issuers that a payments-focused reader will need to track for market-access purposes rather than purely integrity purposes. The uneven provincial beneficial-ownership picture identified by the FATF evaluation also has a bearing on the Crypto Monitor's reading of Canada's corporate-registration requirements for crypto-asset trading platforms, several of which incorporate provincially. #### Outlook The near-term question is implementation rather than enactment. Canada now has, on paper, a materially strengthened AMP regime, a path to universal FINTRAC enrolment, and a stablecoin-specific registration requirement, but none of the last two is in force, and the exact financial-penalty figures in the first remain unreconciled against primary regulation text. The FATF mutual evaluation's regular-follow-up placement gives Canada a multi-year window to demonstrate that the federal beneficial-ownership mechanism translates into consistent provincial practice; whether that happens, or whether the provincial gap persists as a structural feature of the regime, is the fact worth tracking into the next cycle. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Canada's financial-integrity architecture is moving in two directions at once this cycle: toward institutional centralisation, and toward an acknowledgment of structural gaps left standing since the last FATF review. The Financial Crimes Agency Act, Bill C-29, remains before Parliament after first reading on 27 April 2026, and on 8 October 2026 Deputy Minister Rob Stewart named digital-asset tracing as a key early priority for the proposed agency, with a possible launch as early as 2027 depending on passage. At the same time, FATF and the Asia/Pacific Group published Canada's 2026 Mutual Evaluation Report on 29 September 2026, finding considerable progress on beneficial-ownership transparency since 2016 but identifying uneven implementation across provinces and territories as the binding constraint on effectiveness, with a three-year Key Recommended Actions roadmap now set. #### Other Developments The PCMLTFA penalty overhaul continues its roll-out. Bill C-12, in force since 26 March 2026, raised administrative monetary penalties under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act roughly forty-fold, to as much as CAD 4 million per individual and CAD 20 million per entity for a single prescribed violation, with cumulative exposure reaching the greater of CAD 20 million or three percent of global revenue, and up to CAD 30 million or three percent of global revenue for breach of a mandatory compliance order. FINTRAC applies its prior policy to violations occurring wholly before 26 March 2026 and the new framework to everything after. The proposed Financial Crimes Agency would sit alongside, not replace, FINTRAC. Bill C-29 would create Canada's first standalone federal financial-crime law-enforcement body, reporting to the Minister of Finance, with authority to investigate PCMLTFA and proceeds-of-crime offences and to share information with FINTRAC, securities regulators and the RCMP; it remained in committee as of 8 October 2026. #### Cross-Monitor Connections The FINTRAC penalty against Peken Global Limited, operating as the KuCoin exchange, for failing to register as a foreign money-services business and failing to file large-transaction and suspicious-transaction reports, sits squarely at the intersection of this monitor's AML/CFT reading and the crypto monitor's reading of the same enforcement action as a digital-asset compliance event; the appeal to the Federal Court of Canada remained unresolved as of 11 October 2026. Readers of the crypto monitor's Canada page will find the identical underlying FINTRAC action analysed there as a crypto-exchange compliance matter. #### Outlook The FATF/APG three-year Key Recommended Actions roadmap, following the 29 September 2026 Mutual Evaluation Report, gives a dated structure against which Canada's progress on pan-Canadian beneficial-ownership harmonisation, DNFBP risk-based supervision and complex money-laundering prosecution will be tracked ahead of its next follow-up report. Separately, Bill C-29's passage timeline, with a possible 2027 launch for the Financial Crimes Agency, is the development most likely to reshape Canada's institutional AML/CTF architecture over the next twelve to eighteen months; its named digital-asset-tracing priority suggests the new agency's early caseload could include matters currently sitting with FINTRAC alone. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Canada's fifth-round FATF/APG Mutual Evaluation Report, published 29 September 2026 following a November 2025 on-site visit, found the country was not placed under increased monitoring and was recommended for normal, rather than enhanced, follow-up. The report credits Canada with advancing its beneficial ownership transparency framework, pointing specifically to the federal ISC public beneficial-ownership registry, live since January 2024, and to FINTRAC's October 2025 duty requiring reporting entities to cross-check client beneficial-ownership data against that registry. At the same time, the evaluation flags weak effectiveness in risk-based supervision and under-prioritised prosecution of complex money-laundering cases relative to the risk Canada itself has assessed. The combination is architecturally significant rather than incidental: Canada has built structural defences, including a working public BO registry and a cross-check obligation for reporting entities, but the mutual evaluation's own language suggests those defences are not yet translating into supervisory or prosecutorial outcomes commensurate with the underlying risk. A favourable headline outcome on the FATF ledger should not be read as a clean bill on effectiveness. #### Other Developments Recommendation 8 upgrade. Canada improved its rating on FATF Recommendation 8, which concerns the money-laundering and terrorist-financing risk profile of non-profit organisations, from Partially Compliant in the 2021 follow-up assessment to Largely Compliant in the 2026 evaluation. The report nonetheless continues to flag weakness in the oversight of ordinary tax-exempt non-profits that sit outside the Canada Revenue Agency's Charities Directorate registered-charity regime, meaning the upgrade reflects progress within the registered-charity perimeter without yet resolving the broader non-profit-sector gap. Dominant money-laundering typologies. The mutual evaluation states that money laundering in Canada is mainly linked to proceeds from drug trafficking, fraud, commercial trade fraud, and tax crimes, frequently involving organised crime groups and professional money-laundering intermediaries. The explicit reference to professional intermediaries is an enabler-jurisdiction-adjacent signal: it points to facilitators operating within Canada's financial and professional services sectors as a structural feature of the country's laundering risk, distinct from any single enforcement action. Stablecoin framework, standing context. Canada's Stablecoin Act, enacted via Bill C-15 as part of the Budget Implementation Act 2025, designates the Bank of Canada as primary supervisory authority for non-prudentially regulated stablecoin issuers. Implementing regulations are targeted for a 2027 in-force date, and the registry, reserve, and redemption obligations the Act contemplates are not yet operative. No new development occurred within this specific window; this remains carried-forward standing context relevant to Canada's broader financial-innovation and AML perimeter. #### Cross-Monitor Connections The beneficial-ownership transparency progress credited in the mutual evaluation intersects directly with corporate-transparency developments tracked elsewhere: a public BO registry with a reporting-entity cross-check duty is precisely the kind of structural mechanism that other monitors assessing corporate opacity and enabler-jurisdiction risk would want visibility into, since it narrows (without eliminating) the space in which professional intermediaries can obscure beneficial ownership. The mutual evaluation's own identification of professional money-laundering intermediaries as a feature of Canada's dominant typologies is relevant to any enabler-jurisdiction or professional-facilitator tracking undertaken by adjacent monitors, since it names the facilitator channel as structurally significant rather than anecdotal. The standing stablecoin framework, while not active this window, remains a forward-looking point of contact for any monitor tracking financial-innovation or payment-system developments in Canada, given the Bank of Canada's designated supervisory role once implementing regulations take effect. #### Outlook The near-term marker to watch is the maturation of Canada's implementing regulations under the Stablecoin Act, targeted for 2027, which will convert the Bank of Canada's current supervisory mandate into operative registry, reserve, and redemption obligations for non-prudentially regulated issuers. On the AML/CTF side, the mutual evaluation's own flagged gaps, specifically weak risk-based supervision effectiveness and under-prioritised prosecution of complex money-laundering cases, are the structural weaknesses most likely to generate a subsequent enforcement or policy response, since FATF's normal-follow-up recommendation does not require Canada to resolve them immediately but does place them on record for future review. The non-profit sector's continuing oversight gap outside the registered-charity perimeter is a second area where either a policy response or a future evaluation cycle is likely to re-test Canada's progress. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Canada's anti-money-laundering architecture underwent a structural overhaul this cycle. Bill C-12, formally the Strengthening Canada's Immigration System and Borders Act, received Royal Assent on March 26, 2026, significantly amending the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and introducing an unprecedented administrative monetary penalty framework alongside an expansion of FINTRAC's supervisory scope to include financing and leasing companies. This is Confirmed, corroborated by a Tier-1 Public Safety Canada release describing the Royal Assent date and by converging Tier-3 law-firm commentary on the amendment's substance. The overhaul converges with a second structural development: the FATF Plenary of 17-19 June 2026 adopted the joint FATF-APG mutual evaluation report of Canada, its first mutual evaluation since 2016. The outcome and accompanying Roadmap of Key Recommended Actions remain unpublished, expected in the September-October 2026 window. Taken together, a materially raised penalty ceiling and expanded supervisory scope arriving just ahead of a pending mutual-evaluation outcome raises the salience of Canada's AML architecture for correspondent-banking counterparties in the near term, independent of what the evaluation ultimately finds. #### Other Developments FINTRAC enforcement wave against crypto-linked entities. FINTRAC revoked approximately 86 money-services-business registrations in Q1 2026, including 51 in a single action on March 24, 2026, and issued a record CAD 176.9 million penalty against Cryptomus/Xeltox Enterprises alongside a roughly CAD 19.6 million fine against the KuCoin operator. This enforcement wave is enabled by the raised penalty ceiling under Bill C-12 and is reported at Probable confidence from a single Tier-3 commercial-vendor source; the specific penalty figures have not yet been corroborated against a retrieved FINTRAC decision. Sanctions expansion tied to G7 coordination. Effective June 12, 2026, Canada listed seven individuals and more than 30 entities under the Special Economic Measures (Russia) Regulations, targeting energy revenues, the defense-industrial base, disinformation actors, and shadow-fleet shipping participants. This is reported at Probable confidence from a Tier-3 law-firm bulletin; the underlying Canada Gazette or Global Affairs Canada consolidated Schedule 1 text was not directly retrieved this cycle. #### Cross-Monitor Connections The FINTRAC enforcement wave against crypto-linked money-services businesses connects directly to crypto-sector regulatory developments tracked elsewhere: Canada's new Stablecoin Act regime and its existing crypto-trading-platform registration track sit within the same operating environment that FINTRAC's enforcement action targets, though the enforcement finding itself is architectural and enforcement-focused rather than a licensing development. The Bill C-12 AMP overhaul and FINTRAC's expanded scope over financing and leasing companies are also directly relevant to payments-sector supervisory design, given the overlapping population of non-bank payment firms subject to both PCMLTFA reporting obligations and payments-specific licensing regimes. #### Outlook The principal near-term watch item is publication of Canada's FATF 5th-round mutual evaluation report and Roadmap of Key Recommended Actions, expected in the September-October 2026 window; a grey-list or enhanced-follow-up disposition would raise correspondent-bank enhanced-due-diligence expectations toward Canadian counterparties. A second watch item is the phased rollout of additional PCMLTFA regulations giving operational substance to the new AMP framework under FINTRAC's modernisation roadmap, expected through the second half of 2026. Corroboration of the specific FINTRAC penalty figures against a retrieved primary decision would also firm up confidence in the scale of this cycle's crypto-sector enforcement wave. 13 Sep 2026 · fim-2026-09-13 #### Lead Signal Canada delivered its most consequential single-day financial-integrity legislative event of this research window on 26 March 2026, when Bill C-15 and Bill C-12 both received Royal Assent. Bill C-15 enacted the Stablecoin Act, requiring fiat-backed stablecoin issuers to register with the Bank of Canada and, per FINTRAC, to register separately as money services businesses dealing in virtual currency. Bill C-12 amended the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its Administrative Monetary Penalty Regulations, significantly raising maximum AMPs for prescribed violations and codifying a precise definition of anonymous client, closing what had been a longstanding statutory gap. Taken together, the two enactments bring a previously unregulated asset class under supervision while simultaneously raising the cost of non-compliance across the reporting-entity population as a whole. #### Other Developments Sustained sanctions escalation against Russia-linked actors. Global Affairs Canada made repeated amendments to Schedule 1 and Schedule 1.1 of the Special Economic Measures (Russia) Regulations across February, May, June, August and September 2026, progressively adding individuals, entities and shadow-fleet vessels tied to Russia's defense-industrial base, energy revenues, and the forced deportation of Ukrainian children. A June 2026 G7 Summit round added 7 individuals and 34 entities, notably including a first cryptocurrency-financial-enabler designation category alongside the more familiar defense, energy and nuclear designations. Beneficial-ownership transparency continues to expand unevenly. Canada's federal Individuals with Significant Control public registry for CBCA corporations has been operating since 22 January 2024, and British Columbia's own public transparency register, enacted via the 2023 Business Corporations Amendment Act, is now expected to come into force during 2026, extending disclosure beyond the federal and Quebec registers even as full national harmonisation across Canada's federal structure remains incomplete. #### Cross-Monitor Connections The Stablecoin Act's dual registration requirement, Bank of Canada issuer registration paired with FINTRAC money-services-business status, sits directly at the intersection of this monitor's D5 and D7 findings and the crypto monitor's stablecoin_regime tracking; a crypto-issuer that is newly a designated reporting entity is simultaneously a new object of AML/CFT compliance architecture. The June 2026 G7 sanctions round's inclusion of cryptocurrency financial enablers among the defense-industrial and energy-sector designees is a direct evasion-typology signal relevant to any crypto-facing compliance programme monitoring for Russia-nexus counterparties. The sustained multi-round Russia sanctions cadence also connects to conflict-finance and extractive-industry integrity monitoring generally, given the energy-revenue and defense-industrial-base framing of the underlying designations, though no CA-specific conflict-finance development met this cycle's evidentiary bar independently. #### Outlook Watch for the staggered coming-into-force schedule of the PCMLTFA/AMP amendments and the Stablecoin Act's implementing detail through late 2026 and into 2027; reporting entities, including newly-designated stablecoin-issuer MSBs, face a moving compliance target rather than a single effective date. British Columbia's transparency-register implementation during 2026 is a second item to track, since its arrival would narrow, though not close, the gap between Canada's federal, Quebec and provincial beneficial-ownership disclosure regimes. No adverse FATF plenary action on Canada was identified this cycle, and the sanctions cadence shows no sign of slowing. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Canada's sanctions posture against Russia hardened further this cycle. Two amendments to the Special Economic Measures (Russia) Regulations, made in February and March 2026, added more than 200 shadow-fleet vessels in combination, together with 21 individuals and 53 entities, and lowered Canada's independently administered oil price cap from US$47.60 to US$44.10 per barrel (fim-2026-W32-007). This is a High-confidence, Tier-1-sourced finding drawn directly from Global Affairs Canada's own sanctions pages, and it should be read as structural rather than episodic: successive rounds of vessel designation and price-cap tightening indicate a sustained campaign against Russia's shadow-fleet oil-export architecture rather than a single enforcement action. Continue reading Canada then joined a further, G7-coordinated package announced at the June 2026 Évian summit, expanding shadow-fleet vessel designations by roughly 200 additional vessels and pairing the sanctions expansion with a CAD 4.3 billion Ukraine support commitment (fim-2026-W32-008). This development is Assessed rather than High confidence, since it rests on a single Tier-3 source not independently corroborated by a second primary source this cycle; the underlying G7 coordination itself is plausible given the pattern of the February/March domestic amendments, but the specific vessel count and dollar figure should be treated with appropriate caution pending a primary Global Affairs Canada or G7 communiqué citation. Canada's independently-set oil price cap of US$44.10 also diverges numerically from the historical G7-coordinated US$60 baseline, a divergence that has not been fully cross-checked against other G7 members' current cap levels this cycle, leaving open whether Canada is now unilaterally more aggressive than its G7 partners on this specific metric or whether the G7 baseline itself has moved. #### Outlook Watch for whether the G7 Évian vessel-designation figures are confirmed by a primary Global Affairs Canada announcement, and whether Canada's oil price cap is formally reconciled with, or continues to diverge from, the G7-coordinated baseline. Any further Canadian shadow-fleet designations would extend an already-escalating trajectory rather than mark a new development. #### Beneficial Ownership and Corporate Transparency Canada's own beneficial-ownership regime, not the EU's, is the primary subject matter for this jurisdiction's D2 exposure. The federal Canada Business Corporations Act individuals-with-significant-control register has been mandatory since January 2024, and British Columbia is preparing its own public corporate-transparency register for 2026 (fim-2026-W32-005). The structural constraint on both developments is the same: only approximately 14.5 percent of Canadian companies are federally incorporated, meaning the large majority of Canadian corporate beneficial-ownership information remains governed at the provincial level, where registries outside British Columbia and Québec are considerably less developed. This is a High-confidence finding corroborated by two independent Tier-1 government primary sources, and it supports FATF Recommendation 24 relevance directly. Continue reading Globally, the EU AML Package sets the structural direction for beneficial-ownership supervision through three distinct 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, which is progressively shifting supervision of higher-risk obliged entities from purely national authorities toward a hybrid EU-level regime. Canada sits entirely outside this perimeter; no AMLA direct- or indirect-supervision mechanism reaches Canadian entities, and no CA-nexus movement on the EU AML Package was identified this cycle. The Package is included here only as durable backdrop against which Canada's own, structurally partial BO-transparency progress should be read: Canada's federal-plus-provincial patchwork approach stands in contrast to the EU's move toward a more centralised, harmonised supervisory architecture, even though Canada's own reforms are moving in the same general direction of improved transparency. #### Outlook Watch for British Columbia's 2026 public register launch, which would be the first material narrowing of Canada's federal-incorporation coverage gap, and for whether any other province follows with an equivalent registry. No EU AML Package development is expected to directly affect Canada's own BO regime, given the jurisdictions' separate perimeters. #### Enabler Jurisdictions and Professional Facilitators Bill C-12, the Strengthening Canada's Immigration System and Borders Act, received Royal Assent on 26 March 2026 and creates a mandatory FINTRAC enrolment regime for every PCMLTFA reporting entity, extending to the full reporting-entity population a registration analogue that previously applied only to money services businesses; the same legislation raises the maximum administrative monetary penalty to $4,000,000 for serious violations (fim-2026-W32-001). This is an architecture-over-incident development in the fullest sense: it closes a long-standing visibility gap across Canada's entire reporting-entity population, casinos, lottery corporations, and financial institutions alike, rather than targeting any single sector or actor, and it does so through primary legislation rather than regulator guidance, giving it durable rather than fragile standing. Continue reading The practical enforcement consequence of this architecture is already visible in two named FINTRAC actions this cycle. FINTRAC imposed a $91,162.50 administrative monetary penalty against Northern Isga Foundation, operator of the Eagle River Casino and Travel Plaza in Alberta, on 26 March 2026 for AML compliance breaches (fim-2026-W32-002), and a separate $212,025 penalty against the Crown-owned Atlantic Lottery Corporation on 9 July 2026 for three distinct AML compliance breaches (fim-2026-W32-003). Both findings are capped at Assessed confidence because sourcing rests on Tier-3 outlets rather than a primary FINTRAC release, notwithstanding the specificity of the named entities and dollar amounts. Read together, the enrolment mandate and the two enforcement actions confirm that gaming remains a high-risk conduit under active enforcement in Canada, and that a Crown-owned entity is treated no differently from a private operator when compliance failures are found — itself a notable enablement-versus-enforcement signal. Enabler-jurisdiction dynamics beyond Canada's own borders also surfaced this cycle, with direct relevance to Canada's casino-sector risk exposure given shared FATF-network standards. The FATF approved new work at its June 2026 Plenary refreshing its understanding of illicit-finance risk in the casino and broader gambling sector as products expand online and cross-border, a workstream explicitly noted as relevant to Cambodia's long-flagged casino and junket exposure (fim-2026-W32-009); this finding is capped at Low confidence given single-source Tier-3 sourcing. Separately, Laos remained on the FATF Jurisdictions Under Increased Monitoring list per the 19 June 2026 statement, with no removal or escalation action taken this cycle (fim-2026-W32-011); this is also a Low-confidence, single-source Tier-4 finding, logged as continuity rather than change. In three-pillar terms, this cycle's D3 signal is overwhelmingly AML-coded rather than CTF- or CPF-coded: both named FINTRAC penalties and the enrolment mandate sit squarely within anti-money-laundering compliance architecture, and no CPF-specific enabler-jurisdiction finding was located for Canada this cycle. This is a structural under-weighting worth naming explicitly rather than allowing it to pass unremarked: the absence of a CPF signal is not evidence of no CPF risk, only evidence that this cycle's research did not surface one. Canada's first joint FATF/APG mutual evaluation in a decade, adopted at the June 2026 Plenary with publication expected September or October 2026, sits at the intersection of these threads and will likely determine whether Canada's newly enrolled reporting-entity population faces a further tightened supervisory roadmap once the report's Recommended Actions are published. #### Outlook Watch for the formal publication of Canada's FATF/APG mutual evaluation report, expected September or October 2026, and for whether FINTRAC brings further enforcement actions against gaming reporting entities now that mandatory enrolment is in force. Any additional FATF statement on Laos, or further detail on the casino/gambling illicit-finance workstream as it relates to Cambodia, would extend rather than change the current trajectory. ESTMA extractive-payment disclosure regime (CAD 100,000 threshold) standing; no new development this cycle. #### Crypto / Digital Assets / Financial Innovation Canada's digital-asset financial-integrity architecture tightened materially with the 24 October 2026 publication of draft Stablecoin Regulations in the Canada Gazette, operationalising the Stablecoin Act that received royal assent on 26 March 2026. The draft regulations establish a federal registration requirement with the Bank of Canada for non-financial-institution issuers of fiat-backed stablecoins offered to Canadians, replacing what had previously been indirect oversight exercised through provincial securities regulators' gating of value-referenced crypto assets. Substantively, registered issuers must hold reserve assets at a 1:1 ratio in high-quality liquid assets against outstanding stablecoins, offer redemption within three business days, and observe a 1% cap on redemption fees. A ban on holding-based yield applies, with a narrow carve-out preserved for transaction-linked rewards, distinguishing passive-income arrangements (prohibited) from usage-linked incentives (permitted). Continue reading A structurally significant companion element of the draft regulations is their amendment of the Retail Payment Activities Regulations to prescribe stablecoins as a 'unit' for regulatory purposes. This would bring payment service providers performing payment functions using prescribed stablecoins within Bank of Canada supervision under the Retail Payment Activities Act — extending payments-regulatory perimeter coverage to a category of digital-asset-moving firms that previously sat outside it. This extension, however, requires a further Governor-in-Council order before it takes effect, making it a distinct and currently dormant procedural track relative to the core issuer-registration regime. This stablecoin-specific development sits alongside a second, independently sourced signal of tightening digital-asset financial-integrity pressure: FINTRAC's 2025-26 results report shows enforcement activity against money-services businesses concentrated heavily in the virtual-currency sector, with a third-party tracker estimating that roughly 76% of 165 MSB registration revocations in 2026 involved virtual-currency-dealing businesses. Taken together, the draft stablecoin perimeter and the enforcement pattern against virtual-currency MSBs represent two distinct but reinforcing vectors of federal attention to Canada's digital-asset sector: one prudential and preventive, targeting the point of stablecoin issuance; the other punitive and ongoing, targeting existing reporting entities' compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. #### Outlook The 60-day consultation on the draft Stablecoin Regulations, closing 23 December 2026, is the principal near-term milestone, with submissions potentially altering registration, reserve, redemption or fee terms ahead of a targeted fall 2027 in-force date. Separately, the Governor-in-Council order required to activate Retail Payment Activities Act supervision over stablecoin-moving PSPs remains an open procedural step with no confirmed timeline. Given FINTRAC's current enforcement trajectory against virtual-currency MSBs, firms anticipating registration under the new stablecoin regime should expect continued elevated AML/CTF compliance scrutiny to persist in parallel with, rather than be superseded by, the incoming prudential framework. No compliance-technology findings reached within research budget this cycle. #### AML/CTF Regime Bill C-12, the Strengthening Canada's Immigration System and Borders Act, received Royal Assent on 26 March 2026 and amended the Proceeds of Crime (Money Laundering) and Terrorist Financing Act together with its Administrative Monetary Penalty Regulations. The amendment does two structurally distinct things: it significantly raises the maximum administrative monetary penalties available for prescribed violations, and it codifies a precise definition of anonymous client, closing what had previously been a statutory gap in the PCMLTFA's treatment of anonymous accounts. Both changes were confirmed via a T3 law-firm summary that itself cites FINTRAC's own 16 April 2026 publication, giving the finding a Confirmed confidence rating on effectively T1-corroborated grounds. Continue reading The architecture-over-incident significance of this amendment is that it applies across the entire reporting-entity population, not to a single sector or a single enforcement episode. Raising maximum AMPs changes the deterrence calculus for every reporting entity subject to the PCMLTFA, while the new anonymous-client definition removes ambiguity that previously could be exploited or contested in individual enforcement matters. The same 26 March 2026 date also saw the Stablecoin Act receive Royal Assent, meaning the population of PCMLTFA reporting entities gained a new sub-category, stablecoin issuers required to register with FINTRAC as money services businesses, at the precise moment the penalty and definitional architecture around that population was tightened. No FATF plenary action on Canada was identified this cycle, and this tracker's confidence in the absence of adverse action is capped at Uncertain pending fresh primary-source verification, per the structural ceiling noted in the gaps register. The overall trajectory for this domain is worsening from a regulated-entity compliance-burden perspective, even as the underlying policy intent, closing statutory gaps and raising deterrence, represents a tightening of Canada's own AML/CTF architecture rather than a finding of regime weakness. #### Outlook The staggered coming-into-force schedule for these PCMLTFA and AMP Regulations amendments through late 2026 means reporting entities, including the newly in-scope stablecoin-issuer MSBs, face a moving compliance target rather than a single effective date. Watch for further FINTRAC guidance operationalising the anonymous-client definition and the raised AMP maximums as implementation proceeds. No commercial-activity items in this cycle's financial-integrity research. Regulatory horizon Consultation 23 Dec 2026 · ±quarter ### Draft Stablecoin Regulations consultation Stablecoin issuers will register with and be supervised by the Bank of Canada; PSPs performing payment functions in prescribed stablecoins fall under RPAA supervision. [Source](https://gazette.gc.ca/rp-pr/p1/2026/2026-10-24/html/reg1-eng.html) In Force Pending 2026-Q4 · ±half_year ### PCMLTFA / AMP Regulations amendments coming into force (stablecoin MSB registration, higher AMP maximums, anonymous-account definition) Reporting entities, including new stablecoin-issuer MSBs, face materially higher AMP exposure and a codified anonymous-account prohibition. [FINTRAC / Department of Finance Canada Source](https://fintrac-canafe.canada.ca/businesses-entreprises/changes-changements-eng) In Force Pending 2026-Q4 · ±half_year ### FINTRAC AMP policy regulations under Bill C-12 roadmap Additional PCMLTFA regulations giving substance to the new AMP framework, phased per FINTRAC's modernisation roadmap. [FINTRAC / Department of Finance Canada Source](https://www.blg.com/en/insights/2026/04/preparing-for-universal-enrolment-higher-penalties-and-fintrac-enforcement) Proposed 2027-Q2 · ±year ### Financial Crimes Agency Act (Bill C-29) A new ~230-250 person federal agency with authority to investigate any PCMLTFA or proceeds-of-crime offence and broad inter-agency information-sharing powers, funded at CAD 352.7M over five years. [Department of Finance Canada / Parliament of Canada Source](https://www.nortonrosefulbright.com/en-ca/knowledge/publications/e09bd647/legislative-framework-introduced-to-establish-the-financial-crimes-agency) Adopted 2029-Q3 · ±multi_year ### FATF/APG Key Recommended Actions following 2026 Mutual Evaluation Canada will be tracked against this roadmap ahead of its next FATF follow-up report. [FATF / APG Source](https://www.fatf-gafi.org/en/countries/detail/Canada.html) 5 dated · 1 pending date · baseline fim-2026-07-07 Role action cards MLRO ### FINTRAC's 2025-26 results show a sharp rise in enforcement activity concentrated in virtual-currency money-services businesses. The 52% increase in notices of violation and the concentration of MSB revocations in virtual-currency dealing signal that FINTRAC is actively prioritising crypto-asset AML/CTF compliance; reporting entities handling virtual currency should expect continued elevated scrutiny. 2 evidence refs Compliance ### Canada published draft Stablecoin Regulations creating a new federal registration and conduct perimeter for stablecoin issuers. A 60-day consultation to 23 December 2026 precedes a targeted fall 2027 in-force date; firms issuing or planning to issue fiat-backed stablecoins to Canadians should track registration, reserve, redemption and yield-ban requirements as they develop. 1 evidence refs Legal ### The draft Stablecoin Regulations amend the Retail Payment Activities Regulations to bring stablecoin-moving PSPs under Bank of Canada supervision, pending a further commencement order. This creates a distinct, currently dormant supervisory extension with its own procedural trigger separate from the core issuer-registration regime; legal review of PSP exposure should track both tracks independently. 1 evidence refs Board ### Canada is tightening digital-asset financial-integrity oversight from two directions: new stablecoin prudential registration and intensified FINTRAC enforcement against virtual-currency MSBs. Both developments together represent a material strategic shift in Canada's regulatory posture toward the crypto-asset sector, with implications for any institution's Canadian digital-asset business line. 2 evidence refs CTO ### The draft Stablecoin Regulations set specific technical and operational parameters: 1:1 HQLA reserves, three-business-day redemption, and a 1% fee cap. Any stablecoin issuance or redemption infrastructure built for the Canadian market will need to support these parameters once the regime takes effect, including reconciling the yield-ban/transaction-linked-rewards carve-out at the product level. 1 evidence refs Risk ### FINTRAC enforcement and the new stablecoin perimeter together compound regulatory risk concentration in Canada's virtual-currency sector. The combination of sharply increased financial penalties against virtual-currency MSBs and a new prudential registration requirement for stablecoin issuers raises the aggregate compliance and reputational risk profile for any firm operating across both activities. 2 evidence refs Operations ### No material change for this persona this cycle. No material change for this persona this cycle Audit ### FINTRAC's published 2025-26 enforcement results provide a documented audit trail of penalty activity and MSB revocation trends. The published aggregate figures (35 notices, CA$247M, revocation concentration in virtual-currency MSBs) offer a baseline against which internal control-testing scope for virtual-currency-exposed compliance programs can be benchmarked. 1 evidence refs Scenario sketches ### Illustrative pathway: stablecoin registration perimeter meeting AMLA-style supervisory convergence Illustrative only: as Canada's draft Stablecoin Regulations move toward a targeted fall 2027 in-force date, one structural analogue worth orienting against is the European Union's own transition from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly-applicable AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition. Canada sits outside that EU architecture, but the underlying structural question — whether a federal prudential registration perimeter for stablecoin issuers (Bank of Canada) can be effectively coordinated with ongoing AML/CTF reporting-entity supervision (FINTRAC) across the same regulated population — illustrates a generic supervisory-convergence challenge that any jurisdiction building a new digital-asset prudential perimeter alongside an existing AML/CTF regime may face. This is architecture-over-incident framing for analytical orientation, not a prediction of how Canada's own institutional design will evolve. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Sanctions Regime Divergence stable Deemed-ownership aggregate 50% control test clarified by GAC October 2026. T2 · Beneficial Ownership Transparency stable CBCA ISC register and 30-day discrepancy-reporting regime (since Oct 2025) standing. T3 · Enabler Jurisdiction Controls stable PEP/HIO EDD and correspondent-banking shell-bank exclusion duties unchanged; lawyers regulated outside FINTRAC via FLSC Model Rules. T4 · Conflict Finance Disclosure no_change ESTMA CAD 100,000 disclosure threshold standing. T5 · Crypto/Digital Asset AML Perimeter stable Stablecoin Act (commenced_future) and PCMLTFR travel-rule/LVCTR thresholds for virtual currency dealers standing. T6 · Compliance Technology and Active Defence no_change No findings reached this cycle within budget. Registers ### Enforcement actions - 22 Oct 2025 - FINTRAC removed 23 crypto firms from its registry of permitted money-services businesses, as reported by ICIJ ('Coin Laundry'). 24 Mar 2026 - 12 Nov 2025 - 10 Oct 2024 - 30 Jun 2026 - 23 Feb 2026 - 11 Mar 2026 - 23 Feb 2026 - 5 Feb 2026 - 1 Jan 2026 - 25 Jun 2025 - 26 Mar 2026 - 9 Jul 2026 - 24 Mar 2026 - 16 Oct 2025 - FINTRAC assessed a record administrative monetary penalty of approximately CAD 177 million (~US$126 million) against Xeltox Enterprises Ltd., operator of the Cryptomus crypto payment/exchange platform, for multiple violations of Canada's money-laundering and terrorist-financing legislation, including exposure to IRGC-linked Iranian exchange flows. 22 Oct 2025 - FINTRAC struck the registrations of 35 crypto/money-services businesses (12 earlier in the month, 23 in a subsequent tranche) from its registry of firms permitted to provide money services in Canada, following investigative reporting that found dozens of unregistered Toronto-area crypto shops handling large, unmonitored transaction volumes. 24 Mar 2026 - Canada announced new Special Economic Measures (Russia) Regulations designations targeting drone/UAV manufacturers and 100 vessels identified as part of Russia's sanctions-evading 'shadow fleet', coordinated with Ukraine at a G7 foreign ministers meeting. 12 Nov 2025 - U.S. regulators assessed a record $1.3 billion FinCEN penalty (part of a ~US$3.09 billion global resolution) against TD Bank's U.S. subsidiaries for pervasive BSA/AML failures that allowed fentanyl-trafficking, human-trafficking and Ponzi-scheme proceeds to move through the bank, imposing a four-year independent monitorship. Though the consent order predates this baseline's strict 18-month window, the monitorship remains an active supervisory condition shaping the Canadian parent's cross-border AML remediation through the present. 10 Oct 2024 ### Sanctions changes - 23 Oct 2025 - 16 Jan 2026 - 5 Mar 2026 - 4 Sep 2026 - 12 Jun 2026 - 12 Jun 2026 - Canada added Russian drone/UAV manufacturers and 100 'shadow fleet' tanker vessels to its Special Economic Measures (Russia) Regulations designations, announced jointly with Ukraine's Foreign Minister at a G7 meeting in Ontario. 12 Nov 2025 - The EU's 19th sanctions package (23 October 2025) extended designations to Russian energy actors, third-country banks and crypto-asset service providers facilitating sanctions evasion, broadening the EU's toolkit beyond measures currently available under Canada's SEMA regime. 23 Oct 2025 ### Regulatory horizon (register) - Publication of Canada's FATF/APG mutual evaluation report - PCMLTFA / AMP Regulations amendments coming into force (stablecoin MSB registration, higher AMP maximums, anonymous-account definition) - Publication of Canada's FATF 5th-round mutual evaluation report - FINTRAC AMP policy regulations under Bill C-12 roadmap - Canada Stablecoin Act implementing regulations - Financial Crimes Agency Act (Bill C-29) - FATF/APG Key Recommended Actions following 2026 Mutual Evaluation - Draft Stablecoin Regulations consultation - Publication of Canada's 5th-round FATF-APG Mutual Evaluation Report - FATF Roadmap of Key Recommended Actions for Canada - Provincial interconnection of federal beneficial-ownership registry ### Active schemes - [HIGH] Vancouver-based crypto processor as Russia/Iran laundering conduit - [HIGH] Vancouver Model: casino/real-estate trade-based laundering - [HIGH] Legal-profession AML exemption as structural gatekeeper gap - Toronto crypto-to-cash desks feeding cross-border laundering Sources - [Sanctions (restrictive measures) - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures_en) - [McCarthy Tétrault](https://www.mccarthy.ca/en/insights/blogs/techlex/canada-s-aml-reform-advances-bill-c-12-brings-hefty-penalties-and-higher-compliance-expectations-into-force) - [Casino.org](https://www.casino.org/news/canadian-gaming-fintrac-penalty-alberta-casino/) - [Advisor.ca](https://www.advisor.ca/industry-news/regulation/fintrac-sanctions-government-casino-operator/) - [The Globe and Mail](https://www.theglobeandmail.com/business/article-canada-financial-crime-controls-review/) - [Corporations Canada / ISED](https://ised-isde.canada.ca/site/corporations-canada/en/how-find-information-about-individuals-significant-control) - [Chambers and Partners](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/canada) - [Global Affairs Canada](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia-russie.aspx?lang=eng) - [Refdesk.ca](https://refdesk.ca/blog/canada-g7-russia-sanctions-ukraine-aid-carney-june-16-2026-businesses-banks-shipping-compliance-guide) - [ComplyAdvantage](https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/) - [FinScan](https://www.finscan.com/post/regulatory-roundup-july-2026-record-settlements-renewed-sanctions-and-ai-oversight-takes-shape) - [Checklynx](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [Global Affairs Canada](https://www.canada.ca/en/global-affairs/news/2026/03/minister-anand-announces-additional-sanctions-against-russia.html) - [Province of British Columbia](https://www2.gov.bc.ca/gov/content/justice/anti-money-laundering/quick-glance-government-actions/corporate-ownership-transparency) - [Stikeman Elliott](https://stikeman.com/en-ca/kh/canadian-securities-law/newly-minted-canadas-proposed-federal-stablecoin-act) - [https://fintrac-canafe.canada.ca/businesses-entreprises/changes-changements-eng](https://fintrac-canafe.canada.ca/businesses-entreprises/changes-changements-eng) - [https://www.fasken.com/en/knowledge/2026/04/fintrac-provides-information-on-recent-changes-to-canadas-aml-regime](https://www.fasken.com/en/knowledge/2026/04/fintrac-provides-information-on-recent-changes-to-canadas-aml-regime) - [https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia-russie.aspx?lang=eng](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia-russie.aspx?lang=eng) - [https://sanctionsnews.bakermckenzie.com/canada-expands-russia-sanctions-at-g7-summit/](https://sanctionsnews.bakermckenzie.com/canada-expands-russia-sanctions-at-g7-summit/) - [https://www.fasken.com/en/knowledge/2025/03/new-public-transparency-register-for-bc-companies-expected-in-2026](https://www.fasken.com/en/knowledge/2025/03/new-public-transparency-register-for-bc-companies-expected-in-2026) - [Mondaq](https://www.mondaq.com/canada/media-telecoms-it-entertainment/1768924/canadas-aml-reform-advances-bill-c-12-brings-hefty-penalties-and-higher-compliance-expectations-into-force) - [Blakes](https://www.blakes.com/insights/canada-s-new-anti-money-laundering-legislation-significantly-raises-penalties-and-adds-new-violation/) - [Baker McKenzie Sanctions Blog](https://sanctionsnews.bakermckenzie.com/canada-expands-russia-sanctions-at-g7-summit/) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [canada-msb.com](https://canada-msb.com/crypto-exchange-license-canada/) - [Public Safety Canada](https://www.canada.ca/en/public-safety-canada/news/2026/03/legislation-that-strengthens-the-immigration-system-and-border-security-receives-royal-assent.html) - [FATF/APG](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/canada-mer-2026.html) - [Insight Threat Intel](https://newsletter.insightthreatintel.com/p/canada-passed-the-fatf-test-but-is) - [DLA Piper](https://www.dlapiper.com/en-ca/insights/publications/2026/04/canada-enacts-framework-to-regulate-stablecoin-in-bill-c15) - [https://www.fatf-gafi.org/en/countries/detail/Canada.html](https://www.fatf-gafi.org/en/countries/detail/Canada.html) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/canada-mer-2026.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/canada-mer-2026.html) - [https://fintrac-canafe.canada.ca/pen/3-eng](https://fintrac-canafe.canada.ca/pen/3-eng) - [https://www.theglobeandmail.com/business/article-digital-asset-tracing-key-priority-financial-crimes-agency/](https://www.theglobeandmail.com/business/article-digital-asset-tracing-key-priority-financial-crimes-agency/) - [https://www.blg.com/en/insights/2026/05/canadas-proposed-financial-crimes-agency-a-new-era-of-financial-crime-enforcement](https://www.blg.com/en/insights/2026/05/canadas-proposed-financial-crimes-agency-a-new-era-of-financial-crime-enforcement) - [https://www.dlapiper.com/en/insights/publications/2026/03/canada-aml-update-three-bills-make-major-amendments-to-the-pcmltfa](https://www.dlapiper.com/en/insights/publications/2026/03/canada-aml-update-three-bills-make-major-amendments-to-the-pcmltfa) - [https://www.nortonrosefulbright.com/en-ca/knowledge/publications/e09bd647/legislative-framework-introduced-to-establish-the-financial-crimes-agency](https://www.nortonrosefulbright.com/en-ca/knowledge/publications/e09bd647/legislative-framework-introduced-to-establish-the-financial-crimes-agency) - [https://ised-isde.canada.ca/site/corporations-canada/en/how-find-information-about-individuals-significant-control](https://ised-isde.canada.ca/site/corporations-canada/en/how-find-information-about-individuals-significant-control) - [https://coinpedia.org/cryptocurrency-regulation/crypto-regulations-in-canada/](https://coinpedia.org/cryptocurrency-regulation/crypto-regulations-in-canada/) - [https://gazette.gc.ca/rp-pr/p1/2026/2026-10-24/html/reg1-eng.html](https://gazette.gc.ca/rp-pr/p1/2026/2026-10-24/html/reg1-eng.html) - [https://fintrac-canafe.canada.ca/publications/ar/2025-2026-info-eng](https://fintrac-canafe.canada.ca/publications/ar/2025-2026-info-eng) - [https://www.wealthprofessional.ca/news/industry-news/fintrac-penalties-top-247-million-as-financial-entities-draw-the-most/393851](https://www.wealthprofessional.ca/news/industry-news/fintrac-penalties-top-247-million-as-financial-entities-draw-the-most/393851) - [https://laws-lois.justice.gc.ca/eng/acts/R-7.36/index.html](https://laws-lois.justice.gc.ca/eng/acts/R-7.36/index.html) - [https://www.parl.ca/legisinfo/en/bill/45-1/c-29](https://www.parl.ca/legisinfo/en/bill/45-1/c-29) - [Global Affairs Canada](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/dealings-prohibition-interdiction-operations.aspx?lang=eng) - [Global Affairs Canada](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/essential-informations-essentielles.aspx?lang=eng) - [Global Affairs Canada](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/deemed-ownership-propriete-presumee.aspx?lang=eng) - [Financial Action Task Force](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/mer-canada-2026.pdf.coredownload.inline.pdf) - [Global Affairs Canada](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/faq.aspx?lang=eng) - [FINTRAC](https://fintrac-canafe.canada.ca/guidance-directives/client-clientele/bor-eng?wbdisable=true) - [ESC Corporate Services Ltd.](https://www.eservicecorp.ca/beneficialownershipreporting/) - [MNP LLP](https://www.mnp.ca/en/insights/directory/determining-value-corporate-beneficial-ownership-registers) - [TMP Corp.](https://tmpcorp.com/ca/blogs/beneficial-ownership-reporting-canada-2025/) - [gamingcompliance.io](https://gamingcompliance.io/fintrac-pep-and-hio-enhanced-due-diligence-casino-obligations-under-the-pcmltfr/) - [Government of Canada (Justice Laws)](https://laws-lois.justice.gc.ca/eng/acts/p-24.501/section-9.4-20210601.html) - [deepidv](https://www.deepidv.com/media/articles/canadian-lawyer-client-identity-verification) - [Natural Resources Canada](https://natural-resources.canada.ca/sites/www.nrcan.gc.ca/files/mining-materials/PDF/ESTMA%E2%80%93Guidance.pdf) - [Thomson Reuters Practical Law](https://ca.practicallaw.thomsonreuters.com/9-616-5943?transitionType=Default&contextData=%28sc.Default%29) - [Torys LLP](https://www.torys.com/our-latest-thinking/publications/2025/12/canadas-stablecoin-act) - [FINTRAC](https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/travel-acheminement/1-eng) - [FINTRAC](https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/lvctr/lvctr-eng) - [Justice Canada](https://lois.justice.gc.ca/eng/acts/P-24.501/20251001/P1TT3xt3.html) - [Justice Canada](https://lois-laws.justice.gc.ca/eng/acts/P-24.501/section-5.html) - [Justice Canada](https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-184/page-14.html?wbdisable=true) - [Global Affairs Canada](https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/financial-sector-secteur-financier.aspx?lang=eng) - [Coinpedia](https://coinpedia.org/cryptocurrency-regulation/crypto-regulations-in-canada/) - [Wikipedia](https://en.wikipedia.org/wiki/Financial_Transactions_and_Reports_Analysis_Centre_of_Canada) - [Signzy](https://www.signzy.com/blogs/canada-fintract-identification) - [CheckFile.ai](https://www.checkfile.ai/en-CA/blog/suspicious-activity-report-sar-aml-compliance-guide) - [Canada Gazette / Department of Finance](https://gazette.gc.ca/rp-pr/p1/2012/2012-10-13/html/reg1-eng.html) - [FINTRAC](https://fintrac-canafe.canada.ca/individuals-individus/rpt-eng) - [Mayo Law](https://mayo.law/articles/what-is-fintrac/) - [FINTRAC](https://fintrac-canafe.canada.ca/pen/guides/ocm-eng) - [FINTRAC](https://fintrac-canafe.canada.ca/guidance-directives/compliance-conformite/guide4/4-eng) - [FINTRAC](https://fintrac-canafe.canada.ca/guidance-directives/recordkeeping-document/record/msb-eng) - [Department of Justice Canada](https://www.justice.gc.ca/eng/csj-sjc/pl/charter-charte/c12_3.html) - [Parliament of Canada](https://www.parl.ca/documentviewer/en/45-1/bill/C-12/royal-assent) - [Borden Ladner Gervais LLP](https://www.blg.com/en/insights/2026/04/preparing-for-universal-enrolment-higher-penalties-and-fintrac-enforcement) - [DLA Piper](https://www.dlapiper.com/en/insights/publications/2026/03/canada-aml-update-three-bills-make-major-amendments-to-the-pcmltfa) - [Library of Parliament](https://lop.parl.ca/staticfiles/PublicWebsite/Home/ResearchPublications/LegislativeSummaries/PDF/45-1/PV_45-1-C12-E.pdf) - [Wikipedia](https://en.wikipedia.org/wiki/Corruption_of_Foreign_Public_Officials_Act) - [British Columbia Securities Commission / CSA](https://www.bcsc.bc.ca/securities-law/law-and-policy/instruments-and-policies/5-ongoing-requirements-for-issuers-insiders/current/55-315/55315-frequently-asked-questions-about-national-instrument-55104-insider-reporting-requirements-and-exemptions-csa-staff-notice) - [British Columbia Securities Commission](https://www.bcsc.bc.ca/industry/issuer-regulation/requirements-for-reporting-insiders) - [FINTRAC](https://fintrac-canafe.canada.ca/guidance-directives/client-clientele/client/msb-eng) - [GSH Financial](https://gshfinancial.com/insights/beneficial-ownership-registry-2026.html) - [FINTRAC Administrative Monetary Penalty Notice: Xeltox Enterprises Ltd. (operating as Cryptomus) — CA$176,960,190 (imposed 16 October 2025, published 22 October 2025)](https://fintrac-canafe.canada.ca/pen/amps/pen-2025-10-22-eng) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Mutual Evaluation of Canada](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofcanada.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Canada](https://www.fatf-gafi.org/en/countries/detail/Canada.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [FATF](https://www.fatf-gafi.org/en/home.html) - [Russia-linked Payment Processor Cryptomus Likely Behind Launch of Parallel Service Heleket | TRM Labs](https://www.trmlabs.com/resources/blog/russia-linked-payment-processor-cryptomus-likely-behind-launch-of-parallel-service-heleket) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Canada revokes dozens of crypto firms' registrations - ICIJ](https://www.icij.org/investigations/coin-laundry/canada-revokes-dozens-of-crypto-firms-registrations/) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [The U.S. Department of the Treasury's Office of Foreign Assets Control Assesses a Civil Monetary Penalty against an Individual | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251124_33) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories) - [TORONTO DOMINION BANK - Form 6-K - FY2024](https://www.sec.gov/Archives/edgar/data/0000947263/000119312524205498/d855431dex991.htm) - [TORONTO DOMINION BANK - Form 6-K - FY2024](https://www.sec.gov/Archives/edgar/data/0000947263/000119312524236027/d829657dex992.htm) - [FinCEN TD Bank Consent Order, Number 2024-02](https://www.fincen.gov/system/files/enforcement_action/2024-10-10/FinCEN-TD-Bank-Consent-Order-508FINAL.pdf) - [FinCEN Assesses Record $1.3 Billion Penalty against TD Bank | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-assesses-record-13-billion-penalty-against-td-bank) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [Canada poised to create public company registry to curb financial secrecy - ICIJ](https://www.icij.org/investigations/panama-papers/canada-poised-to-create-public-company-registry-to-curb-financial-secrecy/) - [NGOs Praise Canada’s New Corporate Ownership Registry | OCCRP](https://www.occrp.org/en/news/ngos-praise-canadas-new-corporate-ownership-registry) - [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/) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [BOI E-FILING](https://boiefiling.fincen.gov/) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [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/) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Financial Crimes Enforcement Network; Inflation Adjustment of Civil Monetary Penalties | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/financial-crimes-enforcement-network-8) - [Penalties | FinCEN.gov](https://www.fincen.gov/penalties) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [U.S. DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/934806/download?inline=) - [Financial sanctions enforcement and monetary penalties guidance - GOV.UK](https://www.gov.uk/government/publications/financial-sanctions-enforcement-and-monetary-penalties-guidance/financial-sanctions-enforcement-and-monetary-penalties-guidance) - [READOUT: Second Annual FINTRAC-FinCEN Symposium in Washington, D.C. | FinCEN.gov](https://www.fincen.gov/news/news-releases/readout-second-annual-fintrac-fincen-symposium-washington-dc) - [US, Canada Target Russia with Hundreds of Sanctions | OCCRP](https://www.occrp.org/en/news/us-canada-target-russia-with-hundreds-of-sanctions) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [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) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [Questions and answers on the 20th package of sanctions against Russia](https://ec.europa.eu/commission/presscorner/detail/en/qanda_26_876) - [Canada Set to Give Russian Assets to Ukrainian Victims | OCCRP](https://www.occrp.org/en/news/canada-set-to-give-russian-assets-to-ukrainian-victims) - [Russia-related Sanctions Programs | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russia-related-sanctions) - [Q&A on the fifth package of sanctions against Russia](https://ec.europa.eu/commission/presscorner/detail/en/qanda_22_2333) - [Crypto Firm Cryptomus Fined a Record $126 Million by Canada Regulator - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-22/crypto-firm-cryptomus-fined-a-record-126-million-by-canada-regulator) - [MSB Registrant Search | FinCEN.gov](https://www.fincen.gov/msb-state-selector) - [SAR-FAQs-October-2025.pdf](https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf) - [Canada Issues Money Laundering Indicators For Cryptoassets](https://www.elliptic.co/blog/canada-issues-money-laundering-and-terrorist-financing-indicators-for-crypto) - [FinCEN Combats Ransomware | FinCEN.gov](https://www.fincen.gov/resources/fincen-combats-ransomware) - [Canada's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-canada-2016.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [National money laundering and terrorist financing risk assessment](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Nationalmoneylaunderingandterroristfinancingriskassessment.html) - [Money laundering and terrorist financing risks](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Ml-tf-risks.html) - [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html) - [Terrorist Financing Risk Assessment Guidance](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Terrorist-financing-risk-assessment-guidance.html) - [Report: Canada Ill-Equipped In Fight Against Money Laundering | OCCRP](https://www.occrp.org/en/news/report-canada-ill-equipped-in-fight-against-money-laundering) - [1 The U.S. Department of the Treasury’s (Treasury)](https://www.fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf) - [FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-advisory-and-financial-trend-analysis-chinese-money-laundering) - [Shadow Bankers – Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/shadow-bankers) - [FATF REPORT Money Laundering from Fentanyl and Synthetic Opioids November 2022](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money-Laundering-Fentanyl-Synthetic-Opioids.pdf.coredownload.inline.pdf) - [From Dubai to Toronto, inside the crypto-to-cash storefronts fueling money laundering’s new frontier](https://www.icij.org/investigations/coin-laundry/crypto-cash-desk-currency-exchange-money-laundering/) - [Money Laundering from Fentanyl and Synthetic Opioids](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-laundering-fentanyl-synthetic-opioids.html) - [Inflection Point: Global Implications of Scam Centres, Underground Banking and](https://www.unodc.org/roseap/uploads/documents/Publications/2025/Inflection_Point_2025.pdf) - [The Chinese-language Underground Crypto Money Laundering Ecosystem](https://www.chainalysis.com/blog/2026-crypto-money-laundering/) - [Financial Trend Analysis Fentanyl-Related Illicit Finance](https://www.fincen.gov/system/files/shared/FinCEN-FTA-Fentanyl.pdf) - [FinCEN Issues Analysis of Fentanyl-Related Threat Patterns and Trends in Bank Secrecy Act Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-analysis-fentanyl-related-threat-patterns-and-trends-bank-secrecy) - [International reporting template on modern slavery, forced labour and child labour (accessible) - GOV.UK](https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide/international-reporting-template-on-modern-slavery-forced-labour-and-child-labour-accessible) - [Apple, Google Criticize Canada’s Bill C-22 Over Expanded Police Data Access - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-26/apple-google-blast-canada-s-plan-to-expand-police-data-powers) - [Canada's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-canada-2016.html) - [Research and Information Service Research Paper Paper 32/24 13 September 2024](https://www.niassembly.gov.uk/globalassets/documents/raise/publications/2022-2027/2024/aera/3224.pdf) - [1 UNCLASSIFIED | NON CLASSIFIÉ](https://www.unodc.org/documents/treaties/CAE_IEG/Questionnaire_responses/Canada_2026-02-02.pdf) - [EN EN EUROPEAN COMMISSION Brussels, 26.6.2026 C(2026) 4386 final](https://webgate.ec.europa.eu/circabc-ewpp/d/d/workspace/SpacesStore/3b159733-6cdf-4f9e-8b30-80580c0679d8/download) - [Mutual Evaluation of Canada](https://www.fatf-gafi.org/en/countries/a-c/canada/documents/mutualevaluationofcanada.html) - [Money Laundering and Terrorist Financing Through the Real Estate Sector](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Moneylaunderingandterroristfinancingthroughtherealestatesector.html) - [Risk-based Approach Guidance for the Real Estate Sector](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-real-estate-sector.html) - [Webinar on Money Laundering through the Real Estate sector](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Webinar-real-estate.html) - [Methods and Trends](https://www.fatf-gafi.org/en/topics/methods-and-trends.html) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Financial Crimes Enforcement Network 71 U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/Appendix_E.pdf) - [APPENDIx E – CROSS-BORDER FUNDS TRANSFER ...](https://www.fincen.gov/sites/default/files/shared/Appendix_E.pdf) - [Guidance on Obtaining and Retaining Beneficial Ownership Information | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-obtaining-and-retaining-beneficial-ownership) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [NGOs Praise Canada’s New Corporate Ownership Registry | OCCRP](https://www.occrp.org/en/daily/14277-ngo-s-praise-canada-s-new-corporate-ownership-registry) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [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) - [U.S. Launches a Beneficial Ownership Registry | OCCRP](https://www.occrp.org/en/news/us-launches-a-beneficial-ownership-registry) - [FinCEN Issues Final Rule Regarding Access to Beneficial Ownership Information | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-regarding-access-beneficial-ownership-information) - [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) - [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) - [Iran Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions) - [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) - [Additional Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/other-ofac-sanctions-lists) - [Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/archive-of-changes-to-the-sdn-list) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [EU-Canada Comprehensive and Economic Trade Agreement | Access2Markets](https://trade.ec.europa.eu/access-to-markets/en/content/eu-canada-comprehensive-and-economic-trade-agreement) - [OFAC Consolidated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/all-faqs) - [Overview of sanctions and related resources - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-resources_en) - [About OFAC | Office of Foreign Assets Control](https://ofac.treasury.gov/about-ofac) - [Sanctions (restrictive measures) - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures_en) - [Government of Canada, Department of Finance](https://www.canada.ca/en/department-finance/programs/financial-sector-policy/nira-neri/2025/report.html) - [Financial Action Task Force (multilateral first-party assessment of Canada)](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-canada-2016.html) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [TRM Labs](https://www.trmlabs.com/resources/blog/russia-linked-payment-processor-cryptomus-likely-behind-launch-of-parallel-service-heleket) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-10-22/crypto-firm-cryptomus-fined-a-record-126-million-by-canada-regulator) - [ICIJ](https://www.icij.org/investigations/coin-laundry/canada-revokes-dozens-of-crypto-firms-registrations/) - [OCCRP](https://www.occrp.org/en/news/report-canada-ill-equipped-in-fight-against-money-laundering) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-11-12/canada-sanctions-russian-drone-makers-shadow-fleet-vessels) - [European Commission](https://ec.europa.eu/commission/presscorner/detail/en/qanda_26_876) - [ICIJ](https://www.icij.org/investigations/pandora-papers/provinces-pose-threat-to-canadas-bid-to-curb-corporate-secrecy-researchers-warn/) - [FinCEN (U.S. Department of the Treasury)](https://www.fincen.gov/news/news-releases/fincen-assesses-record-13-billion-penalty-against-td-bank) Coverage gaps fim-int-2026-07-05-G001: Outcome of Xeltox Enterprises' Fede… fim-int-2026-07-05-G001: Outcome of Xeltox Enterprises' Federal Court appeal disputing FINTRAC's entity-identity attribution is not yet known, affecting confidence in the Cryptomus scheme's current legal status. [resolved] fim-int-2026-07-05-G002: Qualitative/prosecutorial effective… fim-int-2026-07-05-G002: Qualitative/prosecutorial effectiveness of FINTRAC's 2024 PCMLTFA-amendment-driven disclosure increase (beyond raw volume counts) has not been independently verified. [resolved] fim-int-2026-07-05-G003: No Research-collected pinpoint FATF… fim-int-2026-07-05-G003: No Research-collected pinpoint FATF Recommendation citation numbers (e.g. R.23, R.24) exist for Canada's legal-profession or beneficial-ownership gaps this cycle, preventing obligation_refs population without fabrication. [resolved] fim-int-2026-07-05-G004: Ontario and Alberta's provincial be… fim-int-2026-07-05-G004: Ontario and Alberta's provincial beneficial-ownership registry interconnection commitment status and timeline remain unconfirmed. [resolved] fim-int-2026-07-05-G005: No Canada-specific terrorist-financ… fim-int-2026-07-05-G005: No Canada-specific terrorist-financing prosecution case law was identified within the 18-month baseline window to substantiate CTF-pillar typology claims beyond FATF's general global finding. [resolved] fim-int-2026-07-05-G006: The sanctions_changes[] schema's cl… fim-int-2026-07-05-G006: The sanctions_changes[] schema's closed issuing_body enum (OFAC | OFSI | EU_Council | UN) does not accommodate Canada's Global Affairs Canada SEMA designations, preventing a compliant sanctions_changes row for the Canada-specific shadow-fleet/drone designation. [resolved] fim-int-2026-07-07-G001: T2 EU AML Package (AMLR/6AMLD/AMLA)… fim-int-2026-07-07-G001: T2 EU AML Package (AMLR/6AMLD/AMLA) domain updates were not surfaced this cycle; CA-weighted search budget left EU-specific coverage thin. [resolved] fim-int-2026-07-07-G002: No dedicated D4 conflict-finance fi… fim-int-2026-07-07-G002: No dedicated D4 conflict-finance finding beyond the Houthi/oil-revenue channel was surfaced this cycle; broader non-Houthi conflict-finance coverage is thin. [resolved] fim-int-2026-07-07-G003: sanctions_changes[] entries authore… fim-int-2026-07-07-G003: sanctions_changes[] entries authored by Canada's Global Affairs Canada could not be mapped to the closed issuing_body enum (OFAC|OFSI|EU_Council|UN); Canada-origin sanctions amendments are captured in structured_claims/domain_tracker instead. [resolved] fim-int-2026-07-07-G004: The ratified typology library (fim-… fim-int-2026-07-07-G004: The ratified typology library (fim-typ-001..020) was not available in this interpretation context, preventing typology_observations[] matching this cycle. [resolved] fim-int-2026-07-07-G005: active_scheme_inventory[] entries w… fim-int-2026-07-07-G005: active_scheme_inventory[] entries were omitted because Research did not supply stable scheme_id values for the TBML/Vancouver Model/Huione schemes described in domain_tracker. [resolved] fim-int-2026-07-07-G006: The Vancouver Model finding rests e… fim-int-2026-07-07-G006: The Vancouver Model finding rests entirely on Tier 3/4 secondary sources; no fresh 2026 primary regulatory action corroborates it, capping confidence at Assessed. [resolved] fim-int-2026-07-07-G007: obligation_refs.framework closed en… fim-int-2026-07-07-G007: obligation_refs.framework closed enum has no token for Canadian PCMLTFA/SEMR instruments; obligation_refs left empty on CA-specific claims rather than mis-mapped to a UK/US/EU framework. [resolved] fim-int-2026-08-05-G001: No primary FINTRAC.gc.ca press rele… fim-int-2026-08-05-G001: No primary FINTRAC.gc.ca press release or Canada Gazette Part II text was retrieved this cycle confirming the exact Bill C-12 AMP figures; only secondary law-firm commentary was available. [resolved] fim-int-2026-08-05-G002: UN Panel of Experts (Yemen) / OFAC … fim-int-2026-08-05-G002: UN Panel of Experts (Yemen) / OFAC / OFSI Houthi-linked sanctions-evasion channels were not searched this cycle for the T1 tracker; no material-change or no-change assertion can be made for that sub-channel. [resolved] fim-int-2026-08-05-G003: No qualifying Colombia (Tier D) fin… fim-int-2026-08-05-G003: No qualifying Colombia (Tier D) finding was located this cycle; logged as a coverage gap rather than a fabricated no-change. [resolved] fim-int-2026-08-05-G004: Canada's own sanctions-issuing auth… fim-int-2026-08-05-G004: Canada's own sanctions-issuing authority (Global Affairs Canada / SEMA Regulations) does not map to the sanctions_changes[].issuing_body closed enum (OFAC|OFSI|EU_Council|UN); CA-issued sanctions changes are captured only in structured_claims/domain_tracker rather than sanctions_changes[] to avoid an invalid enum value. [resolved] fim-int-2026-08-05-G005: D4 (conflict finance) and D6 (compl… fim-int-2026-08-05-G005: D4 (conflict finance) and D6 (compliance technology) coverage for Canada specifically was thin this cycle; no CA-specific RegTech/AI-transaction-monitoring guidance development was located. [resolved] fim-int-2026-09-13-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-09-13-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle due to pooled search-budget allocation toward the CA-bound union pass. [resolved] fim-int-2026-09-13-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-13-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (Enabler Jurisdictions), D4 (Conflict Finance) and D6 (Compliance Technology) coverage was thin this cycle and should be prioritised in the next research pass. [resolved] fim-int-2026-09-13-G003: No FATF grey-list action or Canada-… fim-int-2026-09-13-G003: No FATF grey-list action or Canada-specific mutual-evaluation development was identified this cycle; T3 structural ceiling applies to FATF tracker confidence. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (Beneficial Ownership) had no CA-specific development identified within this cycle's search budget. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (Enabler Jurisdictions) had no CA-specific development identified within this cycle's search budget. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): D4 (Conflict Finance) had no CA-specific development identified within this cycle's search budget. [resolved] fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 (Compliance Technology) had no CA-specific development identified within this cycle's search budget. [resolved] fim-int-2026-09-28-G005: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-09-28-G005: Tier-D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle due to search-budget prioritisation on the CA union pass. [resolved] fim-int-2026-09-28-G006 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G006 ({'scheme': 'financial_integrity', 'value': 'D5'}): The CAD $176.9M Cryptomus/Xeltox penalty and CAD $19.6M KuCoin-operator penalty figures rest on a single T3 commercial-vendor source and are not yet corroborated against a retrieved FINTRAC decision. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): T1 tracker Yemen/Houthi sanctions channel (OFAC/OFSI/UN Panel of Experts) was not actively checked this cycle for any Canada-relevant signal. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Canada-relevant Mexico or Colombia TBML/narco-finance signal was identified this window; this is a coverage gap rather than a confirmed absence. [resolved] fim-int-2026-10-11-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-11-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle; pooled search budget was concentrated on Canada per the union JID lock. [resolved] fim-int-2026-10-11-G002: D1 (Sanctions), D4 (Conflict Financ… fim-int-2026-10-11-G002: D1 (Sanctions), D4 (Conflict Finance), D6 (Compliance Technology) and D8 (Commercial Activity) received thin coverage this cycle; no fresh T1 signal located for Canada in these domains. [resolved] fim-int-2026-10-18-G001: No dedicated Tier D (Cambodia/Laos/… fim-int-2026-10-18-G001: No dedicated Tier D (Cambodia/Laos/Mexico/Colombia) searches were run this cycle due to pooled union search-budget allocation across five concurrent consumer briefs. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Exact AMP ceiling figures for the PCMLTFA overhaul diverge between commentary sources (serious-violation figure of CAD 4M vs a CAD 20M entity figure elsewhere); no T1 consolidated regulation text was retrieved this cycle to reconcile. [resolved] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Canada-specific DNFBP/gatekeeper (D3 enabler jurisdiction) finding beyond the FATF ME's general beneficial-ownership comment was located this cycle. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Dedicated Yemen/Houthi-linked sanctions-evasion channel searches were not run this cycle due to pooled search-budget constraints; Canada-specific movement on T1 (Russian sanctions-evasion architecture) could not be confirmed either way. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No FATF mutual-evaluation update for Canada was retrieved this cycle; current FATF standing for Canada is carried forward unverified. [open] fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): No update to Canada's federal beneficial-ownership registry was retrieved this cycle. [open] fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', 'value': 'D6'}): Compliance-technology expectations, sectoral trade sanctions, information-sharing gateways, employee screening cadence, whistleblowing, counter-proliferation specifics and fraud/mule-account duties were not reached within the research budget this cycle for Canada. [open] fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): The Financial Crimes Agency Act (Bill C-29) item rests only on a Wikipedia summary; status and content are not yet verified against an official parliamentary source. [open] fim-int-2026-11-02-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): FINTRAC's reported revocation of ~47-50 crypto-linked MSB registrations in Q1 2026 rests on a single T3 aggregator source (Coinpedia) and has not been corroborated against a FINTRAC primary announcement. [open] FIM-GAP-001 (D3): A Supreme Court ruling constitutionally ex… FIM-GAP-001 (D3): A Supreme Court ruling constitutionally exempts legal counsel, law firms and Quebec notaries from AML/CFT reporting and client-identification obligations, leaving a core gatekeeper profession outside FINTRAC's reporting-entity perimeter. FIM-GAP-002 (D6): The Cullen Commission found FINTRAC receiv… FIM-GAP-002 (D6): The Cullen Commission found FINTRAC received over 31 million individual reports in 2019-20 but disclosed only 2,057 to law enforcement nationally (355 in British Columbia), a severe intelligence-to-action conversion failure that June 2024 PCMLTFA amendments aim to address but whose effectiveness is not yet independently verified. FIM-GAP-003 (D2): Canada's federal public beneficial-ownersh… FIM-GAP-003 (D2): Canada's federal public beneficial-ownership registry under the CBCA covers only federally incorporated companies; the large majority of Canadian companies are incorporated provincially, and major provinces including Ontario and Alberta have not committed to feeding beneficial-ownership data into a national system. FIM-GAP-004 (D6): This baseline could not identify a confirm… FIM-GAP-004 (D6): This baseline could not identify a confirmed Canada-specific jihadist/CTF hawala or NGO-misuse enforcement case within the 18-month window despite targeted searches; Canada-specific CTF typology evidence relies on FATF's general 2025 finding that 69% of assessed jurisdictions show major or structural TF-prosecution deficiencies rather than a Canada-specific incident record. ## Evidence #### Confidence-tiered claims On 16 October 2025 (public notice 22 October 2025), FINTRAC imposed a record CA$176,960,190 (CA$176.9M) administrative monetary penalty on Xeltox Enterprises Ltd. (operating as Cryptomus, formerly Certa Payments Ltd.) for 2,593 violations across 6 contravention types under Part 1 of the PCMLTFA, including 1,068 unfiled suspicious transaction reports in July 2024, 7,557 unreported virtual currency transactions originating from Iran (July–December 2024) contrary to the Ministerial Directive on Iran, and 1,518 unreported large virtual currency transactions of $10,000 or more (under appeal to the Federal Court). [[Source 1]](#sec-sources) Probable · 1 source FATF/APG fifth-round Mutual Evaluation Report of Canada published 29 September 2026; Canada not placed under increased monitoring and recommended for normal follow-up. [[Source 1]](#sec-sources) Probable · 1 source FATF MER credits Canada with advancing its beneficial ownership transparency framework, referencing the federal ISC public BO registry (live since January 2024) and FINTRAC's October 2025 cross-check duty. [[Source 1]](#sec-sources) Probable · 1 source Canada improved on Recommendation 8 (non-profit organisations) from 'Partially Compliant' (2021 follow-up) to 'Largely Compliant' in the 2026 evaluation, though continuing weakness in oversight of ordinary tax-exempt non-profits outside the CRA Charities Directorate's registered-charity regime remains flagged. [[Source 1]](#sec-sources) Probable · 1 source FATF MER states Canada's money laundering is mainly linked to proceeds from drug trafficking, fraud, commercial trade fraud and tax crimes, often involving organised crime groups and professional money-laundering intermediaries. [[Source 1]](#sec-sources) Probable · 1 source Standing context: Bank of Canada designated primary supervisory authority for non-prudentially-regulated stablecoin issuers; implementing regulations targeted for 2027 in-force date; registry/reserve/redemption obligations not yet operative. [[Source 1]](#sec-sources) Probable · 1 source FATF and APG published Canada's 2026 Mutual Evaluation Report on 29 September 2026, finding considerable BO-transparency progress since 2016 but uneven provincial/territorial implementation; three-year Key Recommended Actions roadmap set. [[Source 1]](#sec-sources) Probable · 1 source Bill C-29 (introduced 27 April 2026) would create Canada's first standalone federal financial-crime law-enforcement body; on 8 October 2026 Deputy Minister Rob Stewart named digital-asset tracing a key early priority, with possible launch as early as 2027; bill in committee as of this cycle. [[Source 1]](#sec-sources) Probable · 1 source Bill C-12, in force 26 March 2026, raised PCMLTFA administrative monetary penalties roughly 40-fold (up to CAD 4M/person, CAD 20M/entity for a prescribed violation; up to the greater of CAD 20M or 3% of global revenue cumulative; up to CAD 30M or 3% of global revenue for breach of a mandatory compliance order); FINTRAC applies prior policy to violations wholly before 26 March 2026 and the new framework thereafter. [[Source 1]](#sec-sources) Probable · 1 source Canada placed in regular follow-up; R.17 upgraded NC to C, R.12/15/23 upgraded NC to LC, R.16/20 upgraded PC to LC; R.8 (NPOs) upgraded PC to LC; beneficial-ownership effectiveness flagged as uneven across provinces and territories [[Source 1]](#sec-sources) Probable · 1 source Bill C-12 and Budget 2025 Implementation Act (Bill C-15) received Royal Assent March 26, 2026; AMP ceilings raised (minor violation ceiling CAD 1,000 to CAD 40,000; serious violation ceiling CAD 100,000 to CAD 4,000,000 per one source, CAD 4,000,000/individual and CAD 20,000,000/entity per another); compliance orders and mandatory compliance agreements introduced; universal FINTRAC enrolment and the Stablecoin Act created, both not yet in force [[Source 1]](#sec-sources) Probable · 1 source 23 individuals and 5 entities added May 8, 2026 linked to deportation/forcible transfer of Ukrainian children; 34 entities and 121 vessels added June 12, 2026 as a G7-aligned package [[Source 1]](#sec-sources) Probable · 1 source Federal CBCA public ISC registry (live since Jan 22, 2024) continues to operate; since Oct 1, 2025 FINTRAC-regulated reporting entities dealing with CBCA corporations must compare collected BO information against the ISC registry and report material discrepancies [[Source 1]](#sec-sources) Probable · 1 source Draft Stablecoin Regulations published 24 October 2026, operationalising the Stablecoin Act (royal assent 26 March 2026): Bank of Canada issuer registration, 1:1 HQLA reserves, 3-business-day redemption, 1% redemption fee cap, yield ban with transaction-linked rewards carve-out; 60-day consultation to 23 December 2026; in-force targeted fall 2027. [[Source 1]](#sec-sources) Probable · 1 source 35 notices of violation worth over CA$247M in 2025-26, a 52% increase in notice count over the prior year (23 notices / CA$25M); MSB registration revocations concentrated in the virtual-currency sector (third-party tracker: ~76% of 165 revocations in 2026). [[Source 1]](#sec-sources) Probable · 1 source In force, consolidated current to 2026-07-21, last amended 2026-03-26; administered by FINTRAC. Large virtual-currency transaction reports required at CAD 10,000+ with 24-hour aggregation and 5-working-day filing deadline, in force since 1 June 2021. [[Source 1]](#sec-sources) Probable · 1 source Prohibits Canadians and persons in Canada from transacting with, making goods available to, or providing services to designated persons [[Source 1]](#sec-sources) Probable · 1 source Persons in Canada and Canadians abroad must disclose property reasonably believed linked to a designated person [[Source 1]](#sec-sources) Probable · 1 source An entity is deemed controlled where listed person(s) hold, directly or indirectly, 50%+ shares/voting rights, aggregated across multiple listed persons [[Source 1]](#sec-sources) Probable · 1 source low to medium PF risk [[Source 1]](#sec-sources) Probable · 1 source 25% of voting shares or value, individually or in concert, or control in fact [[Source 1]](#sec-sources) Probable · 1 source FINTRAC reporting entities must report material ownership discrepancies for high-risk CBCA clients to Corporations Canada within 30 days [[Source 1]](#sec-sources) Probable · 1 source Foreign PEPs are automatically high risk; domestic PEPs/HIOs are high risk only if the reporting entity's own risk assessment so finds [[Source 1]](#sec-sources) Probable · 1 source Financial entities must confirm foreign correspondent entity is not a shell bank, gather information, obtain senior-management approval, and document obligations in writing [[Source 1]](#sec-sources) Probable · 1 source Lawyers and Quebec notaries are obliged under self-regulatory Model Rules (client ID/verification, CAD 7,500 no-cash rule), enforced by professional discipline, not FINTRAC [[Source 1]](#sec-sources) Probable · 1 source Extractive entities must disclose payments exceeding CAD 100,000 aggregate per payee per category per year [[Source 1]](#sec-sources) Probable · 1 source Issuers must register with and be supervised by the Bank of Canada before offering stablecoins in Canada [[Source 1]](#sec-sources) Probable · 1 source Travel rule applies to virtual currency transfers of CAD 1,000 or more [[Source 1]](#sec-sources) Probable · 1 source LVCTR filed within 5 working days of receiving CAD 10,000+ in virtual currency, with 24-hour aggregation rule [[Source 1]](#sec-sources) Probable · 1 source minor $40,000; serious $4,000,000; very serious $20,000,000 (entity) [[Source 1]](#sec-sources) Probable · 1 source up to $20,000,000 and 5 years imprisonment on indictment [[Source 1]](#sec-sources) Probable · 1 source 3 business days [[Source 1]](#sec-sources) Probable · 1 source approximately 47-50 registrations revoked in Q1 2026 [[Source 1]](#sec-sources) Uncertain · 1 source True [[Source 1]](#sec-sources) Probable · 1 source two-year effectiveness review and plan [[Source 1]](#sec-sources) Probable · 1 source 2026-04-27 [[Source 1]](#sec-sources) Uncertain · 1 source 2017-10-31 [[Source 1]](#sec-sources) Probable · 1 source