FINTRAC UNIVERSAL ENROLMENT

Universal enrolment
is coming for every FINTRAC reporting entity.

Under Bill C-12 every reporting entity that has AML responsibilities must enrol with FINTRAC. This change is not yet in force, but when it is, all reporting entities (not just MSBs) will be required to enrol with FINTRAC.

what is universal enrolment under bill c-12?

Bill C-12 received Royal Assent on March 26, 2026 and introduced various changes to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) - including, a new Universal Enrolment Framework. 

This means mandatory FINTRAC registration for every reporting entity subject to the PCMLTFA, not just Money Services Businesses (MSBs). Universal enrolment extends the obligation across the full range of reporting entities including: financial institutions, life insurance companies, credit unions, securities dealers, trust and loan companies, real estate companies, mortgage companies, title insurers, BC notaries, accounting firms, finance and leasing, factors, dealers in precious metals and stones, RegTech, casinos, private ABM acquirers, and auction houses.

Enrolment coming in to force will be “coming soon” and every single reporting entity needs to be prepared. The AML Shop can help your business navigate these new enrolment requirements.

Important Note: this new mandatory enrolment requirement is not the same as your business being registered for tech access with FINTRAC’s systems in which you may already be enrolled in. Any business that currently reports to FINTRAC uses their tech systems; presumably, yours may already do so. Universal Enrolment is a new animal - think about the extra steps that MSBs have had to take to enrol with FINTRAC… if you are in a different reporting sector, soon you will be required to do the same.

Bill C-12 Compliance: FINTRAC PENALTIES, effectiveness and universal enrolment

Bill C-12 didn't just add a universal enrolment requirement — it substantially raised FINTRAC's administrative monetary penalties (AMPs) framework, and elevated compliance expectations; programs are now expected to be reasonably designed, risk-based, and effective, not just present on paper.  Compliance programs must be proven effective.

By design, enrolment and enforcement are connected. A complete registry of reporting entities allows FINTRAC to plan examinations and identify entities that it has never engaged with -  which is why FINTRAC examination readiness also matters well before your first enrolment notice or compliance questionnaire arrives.

what TO EXPECT WHEN FINTRAC UNIVERSAL ENROLMENT TAKES EFFECT

When the enrolment framework as outlined under BIll C-12 is in force, expect FINTRAC and industry associations to actively identify entities that have yet to enrol, but are obligated to do so (that’s everyone!) — likely through direct notices, "have you registered?" campaigns, and messaging from trade associations, reinforcing the requirement. Before you know it, the push to enrol will be everywhere.

Some entities will receive these notices without ever having had a prior relationship with FINTRAC, and won't know what's being asked of them, whether they're in scope, or how to respond…and often on a compressed timeline. The AML Shop can help you navigate these requests in an accurate and timely manner - whether you are already engaging with FINTRAC or need to get started.

how THE AML SHOP HELPS

• Assess whether your business has AML responsibilities

• Preparation and management of your FINTRAC enrolment application

• Guidance for responding to FINTRAC notices and compliance questionnaires

• Develop and craft compliance programs that meet Bill C-12’s "reasonably designed, risk-based, and effective" standard

• Support your business through FINTRAC examinations and inquiries

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