On March 26, 2026 Bill C-12 was passed and when these changes come into force the game will change BIG TIME if you are a reporting entity under the Proceeds of Crime Money Laundering and Terrorist Financing act (PCMLTFA).
Entities and businesses that are issued a penalty will need to enter into Mandatory Compliance Agreements, with FINTRAC - among other key updates.
💫 Important Note: Compliance Agreements will be required only when any appeals are complete and penalties are final.
Read on for all the details you need to know, including:
🔶 Mandatory Compliance Agreements for entities that receive an AMP
🔶 NEW Administrative Monetary Penalties (AMPs) 40X higher, reaching up to $30 million or 6% of your company gross global revenue (for those that are issued a penalty and then breach their mandatory compliance agreement order)
🔶 Public disclosure of enforcement orders
Expert Insight 💡 Under your new and mandatory compliance agreement with FINTRAC, obligations are created to remediate and implement new business as usual practices. Don’t lose sight of this important obligation to fix your issues.
We will go into more details on these changes below… but if you are short on time and want to skip the reading, just jump ahead and book a consultation with one of our AML experts to discuss.
Mandatory Compliance Agreements are here 🫡
Under Part 4.1 of the amended PCMLTFA, every reporting entity that pays an AMP must enter a compliance agreement with FINTRAC setting out remedial measures and a Director-determined deadline.
Refusal or failure triggers a compliance order — served, publicised, and entered into the public record under the entity's name.
Remember - as stated above, Compliance Agreements will be required only when any appeals are complete and penalties are final.
Penalties multiplied 40× 💸
Maximum AMPs now reach $40,000 (minor), $4m (serious), and $20m (very serious) per violation. Stack multiple breaches and the cap becomes the greater of $20m or 3% of gross global revenue.
Potential penalties for not meeting mandatory compliance agreement obligations can reach $30 million or 3% of global revenue. Together with the initial penalty, that could mean 6% of global revenue as penalties for non compliance with AML rules.
New standards to meet for AML compliance programs 💎
The legal standard for your compliance program elements has moved from "intended to ensure compliance" to "reasonably designed, risk-based and effective" — a substantive test, not a paper one.
What’s next? ✅
As you can see based on these huge changes to enforcement, FINTRAC just got teeth. We keep them off your throat.
A compliance agreement with FINTRAC creates obligations to remediate and implement new business as usual practices.
We have worked on engagements into the thousands to help companies with their AML compliance and can help yours navigate these new processes and get your shop in order to help keep FINTRAC happy.
If you are worried about the state of your compliance program, have received a FINTRAC compliance questionnaire, notice of examination, a penalty or a mandatory compliance agreement - reach out to our experts today.
