New FINTRAC Compliance Rule: Reporting Listed Person or Entity Property
Starting in 2025, a new FINTRAC compliance rule will require all reporting entities, including Money Services Businesses (MSBs), to report when they hold or control property belonging to a listed person or entity. This reporting requirement strengthens Canada’s ability to enforce sanctions and counter the financing of terrorism, corruption, and other threats to the integrity of the financial system.
The new rule will take effect in two stages:
Who and What It Applies To
This rule applies to all entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, including MSBs. It covers any property, whether physical or digital, that is owned or controlled by a person or entity listed under Canadian sanctions or anti-terrorism laws. That could include everything from funds in a customer’s account to virtual currency, real estate, or even personal effects like vehicles or jewellery.
It doesn’t matter whether the listed individual is a customer, a third-party beneficiary, or simply connected to the asset, if your business controls the property in any way, the obligation applies. Even if your MSB has never dealt directly with listed jurisdictions, you are expected to have procedures in place to detect and respond to potential matches.
The new rule will take effect in two stages:
- March 2, 2025 – Reporting becomes mandatory for property linked to individuals or entities listed under the United Nations Act.
- October 1, 2025 – The requirement expands to include listings under the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (the Magnitsky Law).
Who and What It Applies To
This rule applies to all entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, including MSBs. It covers any property, whether physical or digital, that is owned or controlled by a person or entity listed under Canadian sanctions or anti-terrorism laws. That could include everything from funds in a customer’s account to virtual currency, real estate, or even personal effects like vehicles or jewellery.
It doesn’t matter whether the listed individual is a customer, a third-party beneficiary, or simply connected to the asset, if your business controls the property in any way, the obligation applies. Even if your MSB has never dealt directly with listed jurisdictions, you are expected to have procedures in place to detect and respond to potential matches.
Where to Find the Lists
To stay compliant, MSBs need to actively screen and monitor official lists of designated persons and entities. These lists are publicly available and updated regularly:
What Must Be Reported and When
If you identify property in your possession or control that is linked to a listed individual or entity, you must submit a Listed Person or Entity Property Report to FINTRAC immediately. There is no monetary threshold, the presence of the property itself, regardless of value, is what triggers the obligation.
The report must include:
To stay compliant, MSBs need to actively screen and monitor official lists of designated persons and entities. These lists are publicly available and updated regularly:
- UN Consolidated Sanctions List
- Canada’s Consolidated Sanctions List (Global Affairs Canada)
- Public Safety Canada – Listed Terrorist Entities
What Must Be Reported and When
If you identify property in your possession or control that is linked to a listed individual or entity, you must submit a Listed Person or Entity Property Report to FINTRAC immediately. There is no monetary threshold, the presence of the property itself, regardless of value, is what triggers the obligation.
The report must include:
- The identity of the listed person or entity;
- A detailed description of the property;
- Any additional information you have about how the property came into your possession or control.
Staying Compliant
Now is the time for MSBs to review and update their compliance programs. That includes incorporating sanctions list screening into existing client due diligence procedures, training employees to recognize potential matches and act quickly, and ensuring there are clear steps in place to escalate and report any findings internally. You should also revisit your internal controls to confirm that you’re able to restrict or freeze property if the law requires it.
Even if your business hasn’t encountered this scenario before, FINTRAC expects all reporting entities to be prepared. A proactive approach now will make all the difference once the rule takes effect.
Need help updating your sanctions screening or reporting processes? We work with MSBs to ensure you're ready to meet FINTRAC’s new property reporting obligations in 2025. Get in touch with us today!
Now is the time for MSBs to review and update their compliance programs. That includes incorporating sanctions list screening into existing client due diligence procedures, training employees to recognize potential matches and act quickly, and ensuring there are clear steps in place to escalate and report any findings internally. You should also revisit your internal controls to confirm that you’re able to restrict or freeze property if the law requires it.
Even if your business hasn’t encountered this scenario before, FINTRAC expects all reporting entities to be prepared. A proactive approach now will make all the difference once the rule takes effect.
Need help updating your sanctions screening or reporting processes? We work with MSBs to ensure you're ready to meet FINTRAC’s new property reporting obligations in 2025. Get in touch with us today!
