Canada's AML System: FINTRAC and Cullen

As of September 2026: Bill C-12 received Royal Assent on March 26, 2026; its enrolment requirement for all reporting entities still depends on regulations, and stablecoin issuers must register with FINTRAC once regulations under the Budget 2025 Implementation Act are made. The Financial Crimes Agency Act (Bill C-29), tabled April 27, 2026, was in committee after second reading on June 18, 2026 and is not law. Lawyers remain outside FINTRAC's reporting regime and no enacted change was found. It could not be confirmed from the sources reviewed that BC has created the AML Commissioner or the dedicated provincial investigation unit that Cullen recommended, and BC's Mortgage Services Act takes effect October 13, 2026.

How does the Canadian system work?

Canada’s framework is the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, usually shortened to PCMLTFA. It works like most Western systems. Banks, casinos, money services businesses, realtors and other listed businesses must identify customers, keep records and send reports to FINTRAC, the national financial intelligence unit. The report types (large cash transactions, suspicious transaction reports, and others) are covered on the reporting page.

FINTRAC has two jobs. It analyses reports and discloses financial intelligence to police and security agencies, and it supervises businesses for compliance. It does not investigate or lay charges; the RCMP and other police do that. In 2024–25 it generated more than 6,200 disclosure packages, its largest yearly total, and supervised more than 38,000 regulated entities. That year it also issued a record 23 notices of violation, with over $25 million in penalties.

What did the Cullen Commission find?

In the 2010s BC’s casinos and real estate market became a well-known laundering site, described on the Vancouver Model case page. The province called a public inquiry, the Cullen Commission, whose final report of June 15, 2022 made 101 recommendations. BC counts 68 of them as direct actions for the provincial government. Its themes were a lack of coordination, weak federal enforcement, thin data on real estate and gaming, and gaps around professionals.

The report’s first recommendation was an independent AML Commissioner. Others covered mortgage regulation, source-of-funds checks for real estate agents, a dedicated provincial investigation unit, and a bigger, government-funded Civil Forfeiture Office.

What has actually been done?

Some of it is in place:

• Unexplained wealth orders. BC amended its Civil Forfeiture Act in 2023. Its own page lists four filings by September 2024. See forfeiture and UWOs.
• Real estate. The Mortgage Services Act, responding to Cullen, takes effect October 13, 2026. BC also created a condo pre-sale assignment register.
• Gaming. BC introduced a new Gaming Control Act with ID checks, buy-in limits and verified play, and a transaction monitoring system for casinos.

Other recommendations were not confirmed as done. The sources reviewed do not show whether the AML Commissioner or the dedicated provincial investigation unit exists, and the Vancouver Model case page records that no one has been convicted for the core scheme.

How does Canada track who owns what?

Beneficial ownership is where Canada has moved most visibly.

BC’s Land Owner Transparency Registry began receiving filings on November 30, 2020. People who hold BC land through companies, trusts or partnerships must declare who they are, and the registry is public and searchable. Its operator reports more than 388,000 declarations and 77,000 reports filed. BC’s page calls it the single most important measure against money laundering in real estate. It covers land, so it says nothing about the shell company that owns a bank account.

The federal registry began on January 22, 2024. Federal corporations under the Canada Business Corporations Act must file individuals with significant control, meaning people who own or control at least 25%. Some of it is public through Corporations Canada. Most Canadian companies are incorporated provincially, so the register does not cover them. Since October 1, 2025 businesses reporting to FINTRAC must also report discrepancies between what they find and what the registry shows.

BC’s Transparency Register has required private companies to keep owner lists since October 1, 2020, but only directors, police and certain officials can see them.

See shell companies for why these gaps matter.

Why are lawyers exempt?

Canada first covered lawyers in 2001. In Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, decided February 13, 2015, the Supreme Court held that the rules were unconstitutional as applied to lawyers. It found that they allowed searches of law offices that risked breaching solicitor-client privilege, and conflicted with a lawyer’s duty of commitment to the client’s cause.

No new law has brought lawyers back in, so FINTRAC receives no reports from them. The Cullen Commission called it wrong to say lawyers are unregulated: law societies impose their own rules, including on cash. It also concluded that a reporting regime for lawyers would be very hard to make constitutional and that BC should not try. Yet the gap is a weakness. The commission quoted an international evaluation of Canada that called the exemption a serious concern, because lawyers work in high-risk areas such as real estate transactions, company formation and trust accounts. This is the professional enablers problem in legal form.

What changed in 2026?

Bill C-12 received Royal Assent on March 26, 2026. It raised the maximum penalty per violation under the PCMLTFA from $100,000 to $4 million for a person and from $500,000 to $20 million for an entity, with cumulative caps of 3% of gross global revenue for large firms. It requires compliance programs to be “reasonably designed, risk-based and effective,” requires a compliance agreement after a penalty, and creates a universal enrolment requirement for reporting entities, to be set by regulations.

The Budget 2025 Implementation Act, also assented to on March 26, 2026, requires stablecoin issuers to register with FINTRAC once regulations are made.

Bill C-29, the Financial Crimes Agency Act, would create Canada’s first federal police agency for complex financial crime. The Spring Economic Update promised $352.7 million over five years for it. The bill passed second reading on June 18, 2026 and was before the Justice committee. It is not law yet. Whether a new agency changes enforcement results is the test that matters. For the wider picture, read why detection still mostly fails.

First published September 21, 2026 · Last updated September 21, 2026 · Legal statuses current as of September 2026