FINTRAC sets new penalty framework for PCMLTFA violations
PCMLTFA reporting entities face mandatory agreements for post-March 26 violations
Change
FINTRAC began applying a new administrative monetary penalties framework for PCMLTFA violations occurring after March 26, 2026, following Bill C-12 Royal Assent.
Why it matters
The framework changes how FINTRAC administers prescribed violations after March 26, 2026. Reporting entities that commit prescribed violations after that date must enter mandatory compliance agreements and may face compliance orders, while pre-March 26 violations remain under the existing penalty policy and process.
Implications
- — PCMLTFA reporting entities must treat prescribed violations after March 26, 2026 as triggering mandatory compliance-agreement exposure.
- — Compliance officers must map FINTRAC examination periods against the March 26, 2026 cutoff before assessing which penalty framework applies.
- — Reporting entities under FINTRAC supervisory assessment must prepare evidence against a single compliance-expectation set for the full review period.
Who is affected
- — PCMLTFA reporting entities
- — AML compliance officers at Canadian reporting entities
- — Reporting entities undergoing FINTRAC supervisory assessments
What to watch
- — Royal Assent date: March 26, 2026
- — New framework applies to violations after March 26, 2026
- — FINTRAC updates to AMP policy and new guidance